Document Type
Article
Publication Date
12-2011
ISSN
0745-3515
Publisher
University of Notre Dame Law School
Language
en-US
Abstract
Specifying the content of a requirement or a prohibition up front-e.g. replacing a "reasonable speed" requirement with a fifty-five miles per hour speed limit-can make life easier for enforcers and citizens alike. Recent efforts to substitute international tax rules for decades-old standards may do just the opposite, jeopardizing the "miracle" that is today's international tax regime. Enhanced information exchange and formulary apportionment will undermine the legitimacy that is essential to the success of any international legal regime. A better solution would overhaul the century-old benefits principle to weave enforcement deep into the fabric of the international tax regime. Only then will it meet today's tests as successfully as it once rose to the challenge of double taxation.
Recommended Citation
Steven Dean,
Neither Rules Nor Standards
,
in
87
Notre Dame Law Review
537
(2011).
Available at:
https://scholarship.law.bu.edu/faculty_scholarship/3406
