Abstract
In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical view as to the existence of an “international tax regime”. Has the world changed since then? On the one hand, there is a strong move towards international tax coordination, including multilateral agreements and the creation of new institutions handling international tax policies, like the G20 or the Inclusive Framework on BEPS. On the other hand, there is growing uncertainty and much explicit disagreement about the substantive fundamentals driving international tax policy and an increasingly bitter clash of revenue claims raised by governments. While countries were able to rally around the concept of “value creation” and the “single tax principle” in order to put tax havens in their place, they struggle to find common ground regarding the principles governing the overall allocation of taxing rights at the global level so far.
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