Several chapters have appeared in different form elsewhere and permission to include a revised version in this volume is gratefully acknowledged. Specifically, Chapter 10 is based on “Three Steps Forward, One Step Back? Reflections on ‘Google Taxes’ and the Destination-Based Corporate Tax”, 2 Nordic Tax J. 1 (2016). Chapter 11 is based on “Evaluating BEPS” in Sergio Andre Rocha and Allison Christians (eds.), Tax Sovereignty in the BEPS Era (Kluwer, 2017), 97 (with H. Xu). Chapter 12 is based on “BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition?” 46 Intertax 885 (2018) (with G. Mazzoni). Chapter 13 is based on “Full Circle: The Single Tax Principle, BEPS, and the New US Model”, 1 Global Taxation 12 (2016). Chapter 14 is based on “A Global Treaty Override? The New OECD Multilateral Tax Instrument and its Limits”, 39 Mich. J. Int’l L. 155 (2018) (with H. Xu).
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