We have all become familiar with the expression in the PPT set out in article 7(1) of the MLI and article 29(9) of the 2017 OECD Model  where “obtaining that benefit was one of the principal purposes of any arrangement or transaction”.  Discerning which is a principal purpose is one of the main challenges in…

In the 1980s, a new dimension to profit shifting was introduced in the United States through the establishment of Onshore Offshore Banks. New legislation (called the International Banking Facility (IBF)) allowed banks in the US to maintain two separate sets of accounts. One set capturing all transactions with residents of USA which would be subject…

It is widely accepted that the United States of America is one of the most litigious countries on earth. As of 2010, US residents spent about 2.2% of their GDP (approximately 310 Billion Dollars) annually on litigation costs[1]. There are more lawyers per capita in the United States that any other country in the world….