The Best-Selling International Tax Law eBooks of All Time

In The Hypocritical Hegemon, Lukas Hakelberg takes a close look at how US domestic politics affects and determines the course of global tax policy. Through an examination of recent international efforts to crack down on offshore tax havens and the role the United States has played, Hakelberg uncovers how a seemingly innocuous technical addition to US law has had enormous impact around the world, particularly for individuals and corporations aiming to avoid and evade taxation.

Through bullying and using its overwhelming political power, writes Hakelberg, the United States has imposed rules on the rest of the world while exempting domestic banks for the same reporting requirements. It can do so because no other government wields control over such huge financial and consumer markets. This power imbalance is at the heart of The Hypocritical Hegemon. Thanks to generous funding from COFFERS EU, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes.

Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.