Tax Realism, Not Idealism
Washington DC
Joined March 2014
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C’mon @FT , you can do better than this. If you’re going to write a whole article on US intl tax, at least get it right. If my students wrote this on an exam, they’d flunk.
For those wondering how Ireland plans to spend its windfall from Apple, at least some of the $$ appears to be going to marketing campaign (ads on Bloomberg), encouraging … investment into Ireland
Put the Draghi report on the (lack of) European competitiveness (re EU’s “self-fulfilling” “lack of dynamism”) & the ECJ Apple decision side by side, & it’s hard not to see direct line btwn them
EU competitiveness: Looking ahead - European Commission commission.europa.eu/topics/…
For those curious as to possible US responses to DSTs, I recommend today’s W&M hearing on digital trade, bipartisan voices
Trade Subcommittee Hearing on Protecting American Innovation by Establishing and Enforcing Strong Digital Trade Rules waysandmeans.house.gov/event…
Oops Atkinson, witness at W&M trade hearing, says Treas will be paying for other countries’ DSTs bc “US provides FTC for them”?
Trade Subcommittee Hearing on Protecting American Innovation by Establishing and Enforcing Strong Digital Trade Rules waysandmeans.house.gov/event…
For those of you who thought that Loper Bright might be prompting Treas to be more cautious in stretching its authority in reg writing, the prop DCL regs suggest otherwise. My latest for @TaxNotes
Treasury’s Latest Effort to Prop Up Pillar 2 taxnotes.com/tax-notes-inter…
A great crowd & great day of intl tax discussions, thx to UC Law SF for hosting us, & for the interest in the UF Tax Incubator papers!
Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change uclawsf.edu/event/complexiti…
I start Intro Intl Tax teaching entity class regs, w a roadmap
I couldn’t figure out why the students were all citing 1970s RRs rather than the regs in answering the assigned problem, until I googled the q myself & got the AI generated answer, which referred to … 1970s RRs
There’s a logical flaw in arguing that the US taxes foreign earned income too favorably bc it exempts deemed risk free return on tang inv, to support US adoption of OECD min tax which provides for … more generous exemption for foreign investment
ft.com/content/4190482f-8aa2… via @ft
Great opportunity to get insights into the Apple decision at IFA’s virtual mtg (meeting starts today but panel on ECJ decision is tmrw)
USA Branch of the International Fiscal Association Inc. ifausa.org/events/eventdetai…
If you thought that my art on negotiation process for UN tax convention in this week’s @TaxNotes was overly cynical, this article offers an even more pessimistic take:
Reform of the international tax architecture: the UN fails to reach consensus taxjournal.com/articles/refo…
Curious about the process for drafting a UN framework convention on intl tax but didn’t have time to attend 3 weeks of negotiations? Here’s my take, in this week’s @TaxNotes
Dissecting the U.N. Multilateral Convention Process taxnotes.com/tax-notes-inter…
PS-A staked his future @OECDtax on success of 2-pillar solution, & now that he’s gone he’s warning of its “likely failure”
EU-U.S. Clash Over Tax Policy Appears Likely, Saint-Amans Says | Tax Notes taxnotes.com/tax-notes-today…
I’ve gotten ++ requests for the papers put together as part of UF tax Incubator on options for Intl tax reform; there’s now a single link for them outside the @TaxNotes paywall
tastrapi-upload.s3.amazonaws…
We’ll be discussing them at @ UC Law SF next week, if you missed the 1st time
Here’s the registration link for Sept 12 event @ UC Law SF you’re looking for a great discussion on the best ways to reform our intl tax rules in 2025 and beyond:
uclawsf.edu/event/complexiti…
Lots to think about in this article re future direction of US intl tax policy…
How national security has transformed economic policy ft.com/content/6068310d-4e01… via @ft
We’re taking the show on the road! If you’re on the west coast, pls join us at UC Law SF for great discussion of potential US into tax reforms, a reprise of event hosted by @AEI in June:
uclawsf.edu/event/complexiti…