Scholarship@WashULaw
Is There Implicit Bias Implicit in International Tax Law?
Document Type
Article
Publication Date
2023
Publication Title
Tax Jotwell: The Journal of Things We Like (Lots)
Abstract
As has become almost cliché at this point, the international tax regime is facing a defining moment … spearheaded by the Base Erosion and Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD). While BEPS addresses a wide-ranging number of topics, one of its primary focuses is combating tax havens. BEPS is the successor to the 1998 OECD Harmful Tax Competition project which, unlike the wide ranging BEPS, focused almost exclusively on a “name-and-shame” campaign against tax havens. These anti-tax haven efforts can trace their history back to the enactment of “Subpart F” of the Internal Revenue Code which is typically considered the first concerted anti-tax haven effort. The intellectual force behind Subpart F was Assistant Secretary of Treasury for Tax Policy Stanley Surrey (while he was on leave from the faculty at Harvard Law). Surrey has been referred to as the greatest tax lawyer of his generation; his influence can be felt to this day throughout the tax laws of the United States and the world
Keywords
International Tax, Base Erosion and Profit Shifting Project (BEPS), Implicit Bias, Tax Havens
Publication Citation
Adam H. Rosenzweig, Is There Implicit Bias Implicit in International Tax Law?, Tax Jotwell (June 19, 2023),
Repository Citation
Rosenzweig, Adam H., "Is There Implicit Bias Implicit in International Tax Law?" (2023). Scholarship@WashULaw. 148.
https://openscholarship.wustl.edu/law_scholarship/148