Table of Contents Key Findings Introduction Territorial Tax Systems in the OECD Participation Exemptions and Dividend Deductions Controlled Foreign Corporation Rules Interest Deduction Limitations Country-by-Country Reporting Transfer Pricing Regulations Other Anti-Base Erosion Provisions Past, Present, and Future Proposals to Address Base Erosion — The BEPS Project Recommendations — The European Union: Anti-Tax Avoidance Directive — Proposals in the United States … [read post]

The Interplay between the Fourteenth Amendment’s Due Process Clause and the Fifth Amendment’s Takings Clause: Is the Supreme Court’s Test for “Public Use” Merely Rational Basis? [read post]