This report is a comprehensive explanation of the final INDOPCO regulations and corresponding changes to regulations under sections 167 and 446. The report first provides an overview of the final regulations (Part I), second explains and critiques the rules establishing categories of intangibles costs that must be capitalized (Parts II-VII), third describes certain rules that apply across multiple categories of intangibles costs (Part VIII), and finally explains how capitalized intangibles costs are to be recovered (Part IX).
When governments issue bonds they usually have to provide plenty of disclosure to entice investors. These days this often includes information on the...
We examine the design of lawmaking institutions when advocates have agenda setting power and there is randomness in the status quo laws eligible for...
Donald Trump, a president who has proven himself to be highly transactional and keen on reducing debt, may find a potentially trillion-dollar foreign...
Crosspollination between the transitional justice (tj) and business and human rights (B&H) fields has led to a growing scholarly focus on the role of...
Scholars regard the 1923 League of Nations experts’ report as the origin of the international tax system as we know it. The experts’ report noted the...
This Chapter discusses citizenship taxation as a potential solution to the challenges posed by increasing global mobility and the digitalization of...
In a new paper, we present a novel theory of “purposeful enterprise” to explain why nonprofit enterprises survive and thrive. We define nonprofit...
Academic and market interest in environmental, social, and governance (ESG) investing has grown markedly in recent years. Although less prominent, a...
In this chapter, we put forth a case study of Elon Musk's acquisition of Twitter. We detail the legal and contractual issues that arose as the parties...
The recently-announced $50 billion loan package from the G7 nations to Ukraine fell short of the $300 billion or so hoped for by the designers of its...
Extraordinary times beget extraordinary measures. Multiple national emergencies during the past quarter century have generated a pitched debate as to...
Corporate social responsibility (“CSR”) has a tax problem. The field encourages companies to do more for society than the minimum that is legally...
We introduce altruism into standard models of bargaining and explore its implications for the Coase Theorem. A strict interpretation of the Coase...
Critics of initiatives to diversify corporate boards frequently rely on efficiency arguments. Diversity opponents marshal four principal claims. First...
The number of law firm partners who identify as women has more than doubled since 1993. Will these gender parity advances regress as employers curb...
The history of public policy is littered with failures to solve large-scale social problems using interventions derived from behavioral science...
The Supreme Court has twice held since 2020 that statutory restrictions on the President’s removal power violate Article II of the U.S. Constitution...
As our nation emerges from the shadow of COVID-19, the general public is coming to grips with a stark reality looming over our public schools...