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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*


    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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