New international tax paper posted on SSRN

I've just posted on SSRN a recently-completed paper on international taxation, entitled "The Crossroads Versus the Seesaw: Getting a 'Fix' on Recent International Tax Policy Developments."

It should be downloadable here.  Somewhat on the short side by law professor standards (46 pages), but fairly densely packed with content although, I hope, highly readable for those with knowledge of the field.

I'll be presenting it at the 9th annual symposium at the Oxford University Centre for Business Taxation, in late June, and also at the National Tax Association Annual Meeting in Boston this November.

You can find the abstract at the download site, but as it strikes me at the moment as a bit too long, I'll just say that the main idea is to discuss 4 recent developments in international tax policy, emergent since the manuscript went final for my book, Fixing U.S. International Taxation, which came out in early 2014.  In particular, I use a kind of two-way arrow: how does the analysis in the book help us to understand those developments, and what retrospective light do those developments cast on the analytical structure in the book?

The four events that I isolate for attention are (1) the new wave of U.S. corporate inversions, (2) the OECD's BEPS project, and in particular its focus on "hybrid structures," (3) enactment of the U.K. diverted profits tax, popularly known as the "Google tax," and (4) recent U.S. international tax policy proposals, by the Baucus Staff and the Obama Administration in its 2016 budget, that appear to make use of my ideas (but in ways that I had not specifically anticipated).