Cross Border Tax Radio

Pillar Two Side-by-Side System : Leopoldo Parada

In this episode, we discuss the Pillar Two Side-by-Side System, the competitive advantages it creates for US-parented MNEs, its interaction with Article 32 of the EU Pillar Two Directive and its potential breach of EU law, the strategic position that developing countries may adopt, and the potential implications of the stocktake.   In the highly unlikely scenario that you somehow missed it, Professor Parada’s latest insightful article on the SbS Package and the Irony of Global Tax Cooperation can be accessed here: https://legalblogs.wolterskluwer.com/international-tax-law-blog/the-sbs-package-and-the-irony-of-global-tax-cooperation/

Taxation of Robots : Orly Mazur

Robots are increasingly taking over jobs that were once considered safe from automation. In response, there are growing calls across the globe to impose taxes on robots. I had the pleasure of speaking with Orly Mazur to understand whether taxing robots is really the right solution. Orly, a leading voice on robot taxation, shares her thoughts on the following questions: * What are robots in general? How, if at all, do they differ from artificial intelligence? * Is it possible to define robots for tax purposes? * What is a robot tax? Is it the right policy tool, or are there better alternatives to address the concerns driving calls for such a tax? * What would be an appropriate solution for taxing business profits derived in the source state from the digital presence of robots? Beyond the technical bit, Orly also shares what inspired her to pursue a career in tax law within academia. If you would like to explore the topic further, some of Orly’s amazing work on robot taxation can be accessed here: Taxing the Robots - https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3231660 [https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3231660]  Policy Options to Address the “Robot Threat” -  https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6077126 [https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6077126]

Would Robin Hood Support a Wealth Tax? : Sam Mitha

Should the rich pay wealth tax? You have likely seen this question spark intense debate in policy forums, at dinner tables, or even on LinkedIn. Tax policy expert Sam Mitha answers this question and also shares insightful thoughts on questions such as:  * What are the main reasons wealth taxes have failed in most countries? * Should the UK implement a wealth tax? * Could a global minimum wealth tax curb the race to the bottom in individual income tax rates and prevent capital flight?  The ideals of Robin Hood are often used to defend a wealth tax. Would he have supported such a tax today?Tune in to the episode to hear Sam’s thoughts.  Finally, Sam shares the inspiration behind his decision to pursue a career in tax policy and the teamwork that has shaped his remarkable career.

The LL.M. International Tax Law Journey : Ritu Bharadwaj, Edward Balaba

In this episode, Edward Balaba and Ritu Bharadwaj share the motivating factors behind their decision to pursue an LL.M. in international tax law. They also get candid about the individuals who inspired them and served as guiding lights to help them navigate the many challenges of leaving their home countries to study abroad. Finally, Ritu and Edward share their perspectives on the highly relevant topic of tax activism versus/ and tax scholarship. The goal of this episode is to offer insights for prospective students considering an LL.M. in international tax law. If you’re currently enrolled in an advanced programme in international tax law, why not consider starting your own podcast after completing your studies? You might, perhaps, want to test the waters before fully diving in. Every sixth episode of Cross Border Tax Radio is now available for takeover as a host. In these episodes, guests will share their experiences of pursuing an LL.M. in international tax law. If you’re interested in taking over as a host, please reach out to me via dm on LinkedIn or through email at ankuragarwalpro@gmail.com.

Impact of Individual Mobility on Corporate Residence : John Hayes

The topic of this episode arises from our increasingly interconnected world and the reinventing of our work practices in recent years. The era when the board of directors convened solely in fixed locations, seated around large oakwood tables to make strategic business decisions, has passed. Technology has made it easy to make strategic business decisions for corporations from virtually any location. However, a tax consequence of this convenience is the increased risk of corporations being dual-resident due to the management-based criteria of residency in domestic laws. To navigate through this tax consequence, John Hayes shares his expert insights on crucial questions surrounding the issue of dual residency of corporations. Beyond the technical discussion, John shares how a work-related trip to Chicago involving a major private equity firm, just a month after moving to PwC London, set him up for his remarkable career in international tax. He went on to become the partner-in-charge of the inbound international tax structuring practice of PwC UK. He also shares how a client inspired him not only to become good at what he does but also to continue doing so in his current role as an international tax consultant.