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The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Federalism has generally been characterized as a system of government that is friendly to liberty. It is not obvious, though, why this should be so. Federalism is a form of government where citizens simultaneously reside in at least two governments, each of which has independent authority to tax and to regulate. By contrast, in a unitary form of government citizens face only one government with independent authority to tax and regulate. At first glance, it would seem a bit strange to claim that liberty is more secure when citizens are members of two governments with independent authority than when they are members of only one such government. The relationship between federalism and liberty turns out to be a complex one, and one that is capable of working in either direction. Whether federalism supports or erodes liberty depends on importantly on the institutional framework within which federalist governance takes place. The essays in Federalist Government in Principle and Practice examine this institutionalist theme from both theoretical and practical perspectives.
Each issue concentrates on a different topic.