Retaliatory Tax: Paper Presentation

The presentation examines U.S. retaliatory tax measures, including Sections 891, 896, and 899, under international law principles such as ARSIWA's countermeasure framework. It juxtaposes the 'rule of law' against the 'rule of power,' assessing the legality and proportionality of these measures amidst the backdrop of global tax disputes over DSTs and UTPR from OECD's Pillar 2 initiative. Key insights explore the U.S.'s departure from multilateral processes, reliance on coercive domestic laws,...