Allison Christians

Associate Professor of Law, University of Wisconsin Law School


The Meaning of Enterprise, Business, and Business Profits Under Tax Treaties and Domestic Tax Law (forthcoming, 2011)

Written by: Allison Christians and Yariv Brauner[*] PART I. THE MEANING OF “ENTERPRISE” AND “BUSINESS” IN DOMESTIC NON-TAX LAW The terms ―business‖ and ―enterprise‖ are very widely used in United States legislation[1] Given the prevalence of the terms – business and enterprise, an exhaustive survey of their use in non-tax legislation in ...


Fair Taxation as a Basic Human Right

ABSTRACT This symposium issue explores the limits and possibilities of law and legal institutions in redressing poverty and economic inequality. The following essay approaches the question by considering the ways in which domestic tax policy interacts with internationally-recognized human rights. I suggest that focusing on human rights discourse provides a needed ...


Case Study Research and International Tax Theory

Abstract Over the last ten years, legal scholars have begun to use what they describe as “case studies” in an effort to develop better theories about how governments can or should impose taxation on international activities. The attributes and function of case studies, while well-studied and documented in other disciplines, has ...


Global Trends and Constraints on Tax Policy in the Least Developed Countries

Through decades of tax reform and cross-border collaboration, the world’s wealthiest countries have adopted domestic tax policy norms that meet their mutually beneficial interests. But these norms have introduced rigorous change and increasingly rigid parameters for tax policy in the world’s poorest countries. While much scholarly attention is devoted to ...


Historic, Comparative and Evolutionary Analysis of Tax Systems

1.INTRODUCTION Tax reform is a constant process in most nations as governments continuously revisit their tax systems in response to economic, social, and political forces. Domestic legislative processes involving national lawmakers may be the most obvious source of change in the tax system in any independent nation, but international events, institutions, ...


Taxation as a Global Socio-Legal Phenomenon

Allison Christians [*] Steven A. Dean Diane Ring Adam Rosenzweig This essay makes a proposal that may not be controversial among those with a particular interest in international law, but may be less accepted among those primarily interested in tax law: that international social and institutional structures shape, and are shaped by, historical ...


Hard Law & Soft Law in International Taxation

Why do countries follow the rules they do for international taxation? Are they legally obligated, obligated by something that is not law but is similarly compelling, or not obligated at all? Discussion in international tax literature is increasingly using terms such as hard law, customary law, and soft law in ...

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