Cosmopolitan Rights, Global Tax Justice, and the Morality of Cooperation

This Article addresses two related first-order questions about morality that enable us to discern solutions that address second-order questions in the specific policy context of regulation of tax competition and BEPS: (1) what kind of justice conception has sufficient normative support to undergird regulation attempts of this global phenomenon to ensure cosmopolitan tax rights? (the global tax justice question); and (2) what are the pre-conditions of effective cooperation, not based on immediate self-interest, that eschew a market-based approach to tax competition, enabling background conditions for the morality of multilateral cooperation? (the morality of cooperation question). The Article addresses the global tax justice question by discussing the Rawlsian premises to the concept of tax justice and its developments within the internationalist approach; the Article then shifts the focus on the cosmopolitan challenge to Rawls, which introduces, at least theoretically, the possibility of fundamental rights of global tax justice to then draw conclusions about three available normative options for the governance of tax competition and BEPS, which can be derived from the previous analysis. The Article then addresses the morality of cooperation question by examining current literature about non-self-interested cooperation, extending this analysis to the social sanctioning of tax competition, and concludes by proposing a broad first-order framework for second-order policy decisions

The Use of Cross-Border Corporate Profits and Losses and “Global Corporate Tax Information”: A Game Theory Approach

The paper, proposes a game theory approach based on a concept of Global Corporate Tax Information and analyzes the unilateral strategies a country can select from to regulate cross-border profits and losses in its capacity as a residence-country or as a source-country. A description of the strategies available to residence-countries when there is no exchange of Global Corporate Tax Information is developed in section 2. Section 3 then looks at the interactions of those unilateral strategies of residence and source countries when there is no exchange of Global Corporate Tax Information, and shows that they lead to a stable uncooperative equilibrium as the result of “dominant strategies.” Section 4 emphasizes the strategic importance of Global Corporate Tax Information insofar as it is conducive to effective cooperation in enforcement that prevents aggressive strategies by global taxpayers and shows that such coordination can be backed by multilateral commitment. Section 4 also demonstrates that the Common Consolidated Corporate Tax Base ("CCCTB") can be viewed as a multilateral method for the exchange of Global Corporate Tax Information if approved by at least nine EU countries (i.e. the minimum number of parties required under the “enhanced cooperation” procedure.) Section 5 concludes by proposing that the U.S. could become a party to pre-existing multilateral systems for exchange of Global Corporate Tax Information such as the CCCTB

The Global Architecture of Financial Regulatory Taxes

This Article endeavors to broaden the analysis of available policy tools to address the problems created by financial crises and discusses how, in addition to direct regulation, certain tax measures having a regulatory nature may operate to address the so-called “negative externalities” often associated with those crises. There is a negative externality when an economic agent making a decision does not pay the full cost of the decision’s consequences. In such cases, the cost to society as a whole is greater than the cost borne by the individuals creating the economic impact. In practice, negative externalities result in market inefficiencies or failures since in most cases individuals do not fully take into account the costs of the negative externalities created

The Global Architecture of Financial Regulatory Taxes

This Article endeavors to broaden the analysis of available policy tools to address the problems created by financial crises and discusses how, in addition to direct regulation, certain tax measures having a regulatory nature may operate to address the so-called “negative externalities” often associated with those crises. There is a negative externality when an economic agent making a decision does not pay the full cost of the decision’s consequences. In such cases, the cost to society as a whole is greater than the cost borne by the individuals creating the economic impact. In practice, negative externalities result in market inefficiencies or failures since in most cases individuals do not fully take into account the costs of the negative externalities created

High-pressure behavior of methylammonium lead iodide (MAPbI3) hybrid perovskite

In this paper we provide an accurate high-pressure structural and optical study of MAPbI3 hybrid perovskite. Structural data show the presence of a phase transition towards an orthorhombic structure around 0.3 GPa followed by full amorphization of the system above 3 GPa. After releasing pressure the systems keeps the high-pressure orthorhombic phase. The occurrence of these structural transitions is further confirmed by pressure induced variations of the photoluminescence signal at high pressure. These variations clearly indicate that the bandgap value and the electronic structure of MAPI change across the phase transition.Comment: 23 pages, 9 figure