Monday, August 06, 2018

International tax policy article, part 2, posted on SSRN

I have just now posted on SSRN the second part of my recent Tax Notes / Tax Notes International article discussing U.S. international tax policy.

It's available for download here.

The abstract goes something approximately like this: "This paper, published in Tax Notes on July 9, 2018, is the second half of a two-part paper examining and analyzing the three main international provisions in the 2017 tax act. Part 1 discussed normative frameworks for international tax policy. Part 2, contained herein, focuses on the base erosion and anti-abuse tax (the BEAT), global intangible low-taxed income (GILTI), and foreign-derived intangible income (FDII)."

I am thinking that this may be of greater practical interest than Part 1 to people who are looking, not just for an overview of the major international tax provisions in the 2017 U.S. tax act, but also for what I would say is a genuinely evenhanded assessment of its purposes, virtues, and defects, including suggestions for how the above rules might best be changed if one took as given the broad-gauged policy views that appear to have motivated them.

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  38. Never met any hacker as discreet and fast like this White Collar Hackers. They are called WhiteHats and they has helped me in multiple ways first was when my ex spouse cheated on me- they got me every information from my spouse phone number and now they are helping me paying my credit cards debts. They have the best hacking tools plus service any one can ever imagine and I recommend him to the world. I am thankful and grateful for the second chance. Honestly, WhiteCollar hackers are life savers please contact them here if you need their swift service Email; WhitehatspytechATcyberservicesDOTcom

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  39. I started trading with COINSFM and I have deposited over $128K in total over a 4 month period and my account was about 290k at the best. of course i should have withdrawn when at the top. Most money was won by the help of my Account Manager named David Garcia and in background was the Senior Account Manager Oliver Martin. One Thursday evening, David contacted me after a long break and stated now was the time to make some real money again. After about 4 – 5 hrs the result was a loss of everything except an active trade on XRP worth 80k. I then agreed a recovery plan with Oliver Martin stupid as I was. This plan should be a very low risk plan based on weekly coin buying. The recovery looked promising until Martin introduced me to a total maniac with the name of Rothschield which he claimed would help me get my account back on top. After 2 hours of trading the account was empty again with the exception of a long term stock trading. All in all I’m an idiot trusting these guys. I am 100% sure that I was targeted the day I made my first deposit. When they felt that I was empty (no more to deposit) they decided to strike and did their best to empty the account.
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  44. Anonymous5:31 PM

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  48. Anonymous6:38 PM


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  49. Anonymous7:17 PM

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  51. I'm here to testify about Mr. John Blank ATM Cards which can withdraw money from any ATM around the world.. firstly I thought it was a scam until I saw so many testimonies about how Mr. John sent them the ATM blank card and how it was used to withdraw money in any ATM and become rich so I decided to risk the opportunity I contacted him also and I applied for the Blank Card to my greatest surprise I have used it to get 10,000 dollars. maximum withdrawal daily $1,000, Mr. John is giving out the card just to help the poor. Hack and take money directly from any ATM Machine Vault, If you are interested kindly contact him directly on his email (johnlopez1945@gmail.com)

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  52. Anonymous8:00 AM

    I am open to share my experience with bitcoin investment and losing money to scammers. However, yes it is possible to recover your stolen bitcoins. I never believed in bitcoin recovery because I was made to understand that it was not possible. However, sometime in JumeI fell for a forex scam which promised overly high returns and I ended up losing close to $55,000. I searched for a month for help until I finally came across an article on reddit in regards to recovering stolen cryptocurrency so I reached out to them, vitorzprogrammer @ gmail com, I was so scared and skeptical because I have heard of bad experiences but I decided to give them a try and to my greatest surprise I was able to get all my stolen bitcoins recovered from the scammers within a very short time frame. If you are experience same problem simply contact him Whats App (+1) 519 / / 398 / / 1460

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  53. file my divorce papers with the evidence I got, He also went ahead to get me back some of the lost money I sent to those other fake hackers, every dollar I
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  54. Anonymous7:54 PM

    Hello, my name is Evans from the United Kingdom am here to give a testimonial on how I meet one of the best Hacker so far on my incredible moment of pain I lost a huge amount of money to a fake investor, I invested 105,000 USD to this investment company with my belief that I will have a huge return when it was time for me to get my return they company no longer pick my calls or reply to my email I was so devasted that my sister saw my pain and sad sorrow she have no choice than to introduce me to this great hacker called Wizard Brixton. I tell him everything about my situation and he asked for the company email address and the mobile number he promises to help me retrieval my funds if I will be able to cooperate and give him the vital information needed less than 24 hours he was able to give me the necessary details about the company and how he will get my funds back without the company approval. Contact him: Wizardbrixton@gmail.com WhatsApp with (+1- /807-23 ) 4-0428 ;) I was very happy when he recovered all my funds and gave me 2% of the profit the company could have given to me . so I promise to make him go viral for everyone to contact him in different aspects of hacking software program in your life he proves the best in his job CONTACT HIM: Wizardbrixton@gmail.com

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  55. I just have to introduce this hacker that I have been working with him on getting my credit score been boosted across the Equifax, TransUnion, and Experian reports. He made a lot of good changes to my credit report by erasing all the past eviction, bad collections, and DUI off my credit report history and also increased my FICO score above 876 across my three credit bureaus report you can contact him for all kinds of hacks. Email him here via
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  56. If You Are Trying To Catch Your Cheating Spouse In The Act, I Strongly Recommend You Contact This Awesome Hacker That Helped Me Monitor My Husband’s Phone When I Was Gathering Evidence During The Divorce. I Got Virtually Every Information She Has Been Hiding Over The Months Easily On My Own Phone: The Spy App Diverted All Her Whatsapp, Facebook, Text Messages, Sent And Received Through The Phone: I Also Got Her Phone Calls And Deleted Messages. She Could Not Believe Her Eyes When She Saw The Evidence Because She Had No Idea She Was Hacked, I Didn’t Need To Touch Her Phone At all,.I Certainly Recommend Contact: “WhitehatstechAtgmailDotcom ”

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  57. Anonymous3:45 AM

    Hello, my name is Evans from the United Kingdom am here to give a testimonial on how I meet one of the best Hacker so far on my incredible moment of pain I lost a huge amount of money to a fake investor, I invested 105,000 USD to this investment company with my belief that I will have a huge return when it was time for me to get my return they company no longer pick my calls or reply to my email I was so devasted that my sister saw my pain and sad sorrow she have no choice than to introduce me to this great hacker called Wizard Brixton. I tell him everything about my situation and he asked for the company email address and the mobile number he promises to help me retrieval my funds if I will be able to cooperate and give him the vital information needed less than 24 hours he was able to give me the necessary details about the company and how he will get my funds back without the company approval. Contact him: Wizardbrixton@gmail.com WhatsApp with (+1- /807-23 ) 4-0428 ;) I was very happy when he recovered all my funds and gave me 2% of the profit the company could have given to me . so I promise to make him go viral for everyone to contact him in different aspects of hacking software program in your life he proves the best in his job CONTACT HIM: Wizardbrixton@gmail.com Real Hacker

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  58. We are professional ,we get your work done in less than 24 hours. We provide the following services and more;
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    * FREE BITCOIN LOADING AND PAYPAL LOADING, WE SHARE ON %.
    * MOBILE PHONE MONITOR/HACK.
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    * HACK INTO ANY BANK WEBSITE AND DO MONEY TRANSFER.
    * HACK INTO ANY COMPANY WEBSITE.
    * HACK INTO ANY GOVERNMENT AGENCY WEBSITE.
    * HACK INTO ANY DATABASE SYSTEM AND GRANT YOU ADMIN PRIVILEGES.
    * HACK PAYPAL ACCOUNT.
    * HACK WORDPRESS BLOGS.
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    *Increase Credit Scores
    *western union, bitcoin and money gram hacking
    *criminal records deletion
    *BLANK ATM/CREDIT CARDS
    * Untraceable IP and so much more....
    * We can restore LOST FILES AND DOCUMENTS , no matter how long they have been missing.
    NOTE:
    If you refer a client to us as a result of the previous job done for you, you will stand a chance of getting any job of your choice hacked for you free of charge.
    We can also teach you how to do the following with our ebook and online tutorials
    * Hack and use Credit Cards to shop online.
    * Monitor any phone and email address.
    * Hack Android & iPhones.
    * Tap into anybody’s call and monitor their conversation.
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    WhatsApp: +1(539) 888-2243

    ReplyDelete
  59. Christian Garreth is my name and i reside here in Los Angeles, i work as a dispatcher and got dropped down from work in regards to Covid-19 but before the incident i was able to save some funds hoping to invest someday into some good business that can really brings out good income, before I got dropped from my job due to covid-19 i came across a broker trading site which deal on cryptos and i signed up with the site and a representative called me, it was a female voice, she made me feel comfortable and i trusted the process so i decided to invest with $8500 in Bitcoin, after three months of loosing my job i decided to make a withdraw and i was ask to pay more then i did until i noticed i have paid $46,980 US Dollars which led me into debt and the worst of all was that the whole thing was a scam so i decided to look for a means to get my funds back. then i came across several hackers online about 4 of them who took my money and take advantage of my situation, i totally gave up and i lose my apartment along the process so i was squatting with a friend of mine who works at a grocery shop, it was my lucky day when i got referred by someone close to me to email wizardharry (@) programmer (.) net or WhatsApp him +1- (807) 808 - 6168, i did as instructed and when i explained everything to him, he only asked me for details and the cost of the services and it was very affordable and understood by me so i decided to give it a try, a try turns out to be something great and bigger than my expectation. today I'm a happy man and all my funds were recovered by him and my life changed for good. please don't fail to contact wizard harry for scam funds recovery.

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  60. Recovery Lost Funds From Online Scammer's/ Cryptocurrency/ Recovery of Stolen bitcoin / Bitcoin Mining/ Increase your Credit score/ MOBILE SPY REMOTE CONTROL ACCESS AUTHORIZATION. Removing Bad Records from Both Public and Private database via Email: wizardwilliammitnickquick23@gmail.com. or text him on WhatsApp +1(559) 851-5537 he is very trustworthy.

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  61. Cyberspaceshield is a company with group of certified hacker, who are always ready to assist you with all your cyber problems.

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  62. IS IT POSSIBLE TO GET A SUCCESSFUL RECOVERY OF YOUR FUNDS LOST TO FAKE/ILLEGAL CRYPTO WEBSITES OR ANY ONLINE FRAUDSTER/ FRAUDSTERS?
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    🔹OUR SERVICES🔹
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    DISCLAIMER: Bloomberg Incorporations accepts no responsibility for any information, previously given to anybody by clients on as regarding the job. Bloomberg Inc. will not distribute contact information collected on any hacking job other than in the Bloomberg Hacker's listings themselves, and will not sell contact information to third parties.

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    All rights reserved.

    ReplyDelete
  63. Never met any hacker as discreet and fast like this Best System Hackers. They are called Best System Hacks and they has helped me in multiple ways first was when my ex spouse cheated on me- they got me every information from my spouse phone number and now they are helping me paying my credit cards debts. They have the best hacking tools plus service any one can ever imagine and I recommend him to the world. I am thankful and grateful for the second chance. Honestly, Best System hackers are life savers please contact them here if you need their swift service Email; BESTSYSTEMHACKSOLUTION@GMAIL.COM or text him on WhatsApp +1 (602) 609-4730 he is very trustworthy.

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  65. Anonymous10:55 AM

    BARNESHACK INTEL is a Group of Multinational Hackers. An affiliate of Evil Corp. We make sure by all means necessary that our clients get the best of services on A PAYMENT AFTER JOB IS DONE BASIS. Rather than send money and trust a criminal to fulfill your deal, you can make sure the job is done before WORKMANSHIP is paid for. You'll get excellent customer service.
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  66. You can contact Bestsystemhacksolution@gmail.com for your hacking problems he helped me to investigate my spouse when he was cheating on with me he helped me to hack his phone without him knowing and he sent me messages from his social media apps plus he helped me in boosting my credit score he is the best just trust me you can contact via his email or Whats App +16026094730.

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  68. I am very pleased with the help CYBER CREDIT GURU rendered in restoring my credits. I am a disabled Veteran who over the past 2 years had to let my credit go due to health priorities that were not covered by VA & other insurance, my credit scores were 514 Experian, 515 Equifax, and 518 TransUnion. No public records, only 3 open Accts but several collection Accts with Zero Balances, few Weeks ago, I ran into some Credit blogs on the net which led me to CYBER CREDIT GURU the most talked about US based Russian hacker, who tremendously repaired and upgraded my credit score to 784, 789, and 802 within the 3 Bureaus in just a Week after I contacted him. If faced with similar challenge, connect with him via: C Y B E R C R E D I T G U R U (AT) G M A I L (DOT) C O M or Call / Text: +1(650) 239 7249 you too can be helped, I recommend him without hesitation.

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  70. Contact this guy for problems such as hacking emails, Facebook, Twitter, Instagram, note changes, deleting criminal records, credit and debit refill, reloading insurance documents, lost or lost file recovery, background check of people and organizations Monitor your spouse's activities regarding the phone and social media and contact him at albertgonzalezwizard (@) gmail com or whatsapp +31684181827 Telegramm:  +31687920980 he is very trustworthy.

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  72. I don’t care what you all think, but Everyone make Mistakes .
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  73. I strongly recommend the service of a GREAT Hacker to you
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  75. Hello everyone, My name is Amber Shaw, i Went through a divorce and found out that my Ex trashed my credit, In December when I took back my financial life, I was ruined, I discovered my FICO score was at 533, all account was late, over limit, mostly charge offs, Debts was worth $60k... Immediately I put a plan of action on how to fix my credit, because I needed a car for myself but with my current credit score then I won’t get approved due to the charge offs and debts coupled with low credit score in my credit reports, well thanks to Mr Juuso Kröger who was there for me when I needed him the most. After i spoke to Marja a friend of mine from Finland i explained my situation to her, she introduced me to a renowned professional hacker Mr Juuso Kröger, immediately I contacted them via: Jkrogerwizard001@gmail.com and also texted on +1 210 600 1803, I got replied same day and I explained myself and they promised to get the job done Within 2 weeks my credit score changed, charge offs were deleted from my report, all debt cleared and my credit score was raised to 815 across the 3 credit bureaus. My car loan has been approved, I’m super excited to jump into my 2019 Mazda CX-5 which was my dream car at that so i would recommend you contact him with all types of hacking job you want and you will smile.

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  77. HOW DO YOU RECOVER YOUR MONEY FROM A SCAM?

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  78. BINARY SCAM RECOVERY

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    ReplyDelete
  79. 🟢Hire the best and fastest HACKERS on the web today. We give you HACKING SERVICES better than any HACKING group you can find in the internet. Our HACKERS are available for 24/7, always ready to attend to you at any time of the day, anywhere in the world.

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  80. He is the best out there,I tested him and he delivered a good job,he helped me settle bank loans,he also helped my son upgrade his scores at high school final year which made him graduate successfully and he gave my son free scholarship into the college,all I had to do was to settle the bills for the tools on the job,I used $500 to get a job of $50000 done all thanks to Robertson he saved me from all my troubles,sharing this is how I can show gratitude in return for all he has done for me and my family
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  81. Anonymous3:25 PM

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  82. Need a Prö hacker? A senior member of the Anonymous hacking group is at your service [Contáct Anonymoushacker72@protonmail.com or 708-967-3006 Text Only]
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    ReplyDelete
  83. HOW DO YOU RECOVER YOUR MONEY FROM A SCAM?

    It’s a question you wish you didn’t have to ask, but it’s a necessary one if you’ve been scammed. I’ve seen my fair share of internet scams over the years, so I know how it feels. The good news is, I also know some practical ways you can go about getting your money back from the scammers.
    There are many types of scams online. From your typical ‘get rich quick scams, to investment and dating scams. The list goes on and on. You name it, there’s probably a scam for it. But regardless of what type of scam you’ve fallen victim to with the right information, you’ll be able to recover your funds back.
    It can be an absolutely terrible feeling when you get scammed online, especially if it’s your first time. But you can get it back if you follow the guidelines I’ll show you.

    Firstly, when you notice you’ve been scammed online or involved in online fraud one way or the other and in the process you lost your funds, the first thing you’ll need to do is contact any law enforcement agency close to you. The chance of law enforcement to recover your funds back into your account is slim so you don’t have to depend on them to recover your funds but it’s always good to report the case no matter how embarrassing the scam might be.

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    After a forensic investigation is carried out by the firm and your claim is found to be legitimate the recovery process will commence. Also take into consideration that the entire process could take a couple of weeks but in the end, you get to recover over 80% of your lost amount.

    ReplyDelete
  84. I humbly implore your attention to discuss with you a great hacker called Wizard Brixton who helped me in recovering my funds when I trusted a faker rippers who rip out my money and I was broke and could not even afford to pay my rents or to feed myself my girlfriend left me because there was no hope anymore lost all my life saves to this ripper but suddenly I saw an advert about this hacker and I contact him on wizardbrixton@gmail.com and explain my situation to him, he said that he will help me to recover my funds and I think is just a normal way hacker do say but suddenly Brixton got me proof to show he can get my funds, at last, he recovers my 357,000 USD from the rippers and it was a shock to me so I promise him to sing the praise of him so other people can benefit from his good job email him directly via WIZARDBRIXTON (AT) GMAIL (DOT) COM and reach him on WhatsApp +1- /807-23 4-0428 Immediately for your help and discuss further

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  85. Hello friends, I’m from London and I’m using this medium to testify to the genuine work of an Hack Pro and PIA.When it comes to hacking although, I never believed it could be possible for me to access someone device without touching it but after contacting the hack pro (Larrywizardhacking57@gmail.com), now I know better.They hack all social media platforms, smartphones, bank Accounts, help recover stolen crypto and even more.
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  86. Anonymous12:35 AM

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  90. Anonymous10:05 AM

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  91. Anonymous2:56 AM

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  94. Anonymous12:17 PM

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    (at)killhacks | 752822040 I>C>Q
    (at)Leadsupplier | (at)killhacks TLGRM
    bigbull0334 (at) onion mail . org E.mail

    CC CVV's with billing address (USA|UK|CANADA)
    SSN DOB DL ADDRESS USA
    SIN DOB ADDRESS MMN CANADA
    NIN DOB ADDRESS SORT CODE UK
    HIGH CREDIT SCORE PROS 700+
    YOUNG AGE FULLZ 2002+
    BUSINESS EIN COMPANY FULLZ USA
    CLONING CARDS DUMPS WITH PIN TRACK 101 & 202
    SBA|PUA|UI|UBEREATS|DOORDASH PROFILES
    TAX RETURN FILLING PROS
    REAL DL|ID FRONG BACK WITH SELFIE USA|UK|CANADA
    REAL PASSPORT PHOTOS
    SPECIFIC INFO AVAILABLE IN BULK (AGE|GENDER|DOB|CITY|ZIP)
    OLD AGE & YOUNG AGE FULLZ AVAILABLE
    DEAD FULLZ
    GLOBAL REAL ID'S FRONT & BACK
    CARDING & LOAN METHODS
    SPAMMING TUTORIALS
    SCRIPTIING METHODS & TUTORIALS
    SCAM PAGES
    SMTP|RDP|C-PANEL|WEB-MAILER
    BULK SMS SENDER|EMAIL SENDER

    Quality stuff available
    Payment upfront (BTC|USDT|ETH|LTC)
    Many other stuff we can provide on demand

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