One nation among many : policy implications of cross-border tax arbitrage

Resource Information

The work One nation among many : policy implications of cross-border tax arbitrage represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

One nation among many : policy implications of cross-border tax arbitrage

Creator

• Ring, D.M

Subject

• international tax law
• tax arbitrage
• tax policy

Language

eng

Summary

Cross-border tax arbitrage arises where a transaction is subject to two or more countries' differing tax regimes. Conflicts between the tax rules create unique opportunities for the parties to engage in profitable tax planning - opportunities that would not be available if the transaction occurred entirely domestically in one of the countries. These opportunities have been a growing feature of the multi-jurisdictional business world and have raised issues concerning whether and how countries, such as the United States, should respond. This article examines cross-border tax arbitrage in the context of both domestic tax policy and of other international tax issues, and considers potential repsonses. It proposes an analytical framework for cross-border tax arbitrage based on specific case studies. The article concludes by proposing a balancing test for determining the appropriate treatment of specific instances of cross-border tax arbitrage

Citation source

In: Boston College Law Review. - Boston. - Vol. 44 (2002),

Geographic coverage

International

Language note

English