Project 1: Tax Treaties between the United States and Developing Countries
The United States has over sixty bilateral income tax treaties in force today. Nearly half of these are concluded with developing countries. This project investigates one central question: do these treaties restrict domestic taxing rights of the developing countries?
Project 2: The Relevance of the OECD Two Pillars to the Asymmetric Tax Treaty Problem
The "asymmetric tax treaty problem" is a circumstance in which a bilateral income tax treaty concluded between a capital importing and a capital exporting country restricts the taxing rights of the former. This is a problem of particular concern to developing countries. A recent reform attempt of the "international tax system" is the "Two Pillars" led by the OECD. This paper assesses whether the "Two Pillars" address the asymmetric tax treaty problem, and argues that they are of limited relevance to this problem.
Project 3: The Size of Income Tax Law
This short paper investigates literally what its name suggests: the size of income tax law, ie how long the text of an income tax law is. This is particularly interesting (and amusing) when different countries are compared. One wonders why income tax laws of some countries include thousands of pages and millions of words, whilst other countries manage to keep their income tax laws to a fraction of that size. Of particular current relevance is a comparison between the size of income tax laws in developing countries and the size of various OECD documents.
Project 4: The Doctrine of Economic Duress and International Tax Standard-Setting
In English contract law, the doctrine of economic duress suggests that, where one party uses superior economic power in an "illegitimate" manner to coerce the other party to agree to a particular set of terms, the validity of those terms may be undermined. This project does not attempt to prove that economic duress has occurred in international tax standard-setting. Rather, it uses this contract law doctrine as a point of reference to provide new perspectives to view international tax standard-setting.
Project 5: Comparative Income Tax Law in Developing Countries: Origins and Structures
Income tax laws of developing countries often reflect an influence from former colonial powers or technical assistance by international organisations. My PhD research shows that these laws often lack clarity and do not satisfactorily deal with issues that arise in a modern society. This project aims to compare how these laws deal with certain fundamental issues that any income tax law has to deal with and identify main sources of ambiguity in these laws. Existing comparative tax law works focus primarily on developed and G20 countries. This project aims to reduce that gap.