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17 Asper Rev. Int'l Bus. & Trade L. 131 (2017)
Faltering Blocks in the Arguments against Unitary Taxation and the Formulary Apportionment Approach to Income Allocation

handle is hein.journals/asperv17 and id is 139 raw text is: Faltering Blocks in the Arguments against Unitary Taxation and the Formulary Apportionment Approach to Income Allocation ALEXANDER EZENAGU* SYNOPSIS Tax treaties represent a highly developed area of international cooperation. They are the primary means by which countries cooperate to avoid double taxation and remove barriers to international business, but they have also become tools used by multinationals to avoid or evade taxation on a global scale. Integral to the present day model of tax treaties is the separate accounting and arm's length standard of income allocation (SA-AL), adjudged to be fraught with challenges and accountable largely for the widespread tax evasion and avoidance practices of the modern era. While this existing method for measuring and taxing the income of multinationals is increasingly unsatisfactory, viable alternatives have traditionally been rejected as equally unworkable. This paper will make the case that the alternatives are actually becoming increasingly viable and should be adopted going forward, despite the * Alexander Ezenagu is a PhD Candidate in International Tax Law at McGill University and holds a Master of Law degree (LLM) from the University of Cambridge. His doctoral research focuses on national and international tax law and policy issues, with emphasis on the relationship between taxation and economic development and the role of government and non-government institutions and actors in the creation of tax policy norms.

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