ESSAYS IN INTERNATIONAL TAXATION

The LL.M International Tax Program (ITP) at the New York University, which has twenty-five Years of existence, is to date one of the world s most renowned and prestigious graduate programs for the study of tax law on a global perspective. In the words of its Director, Prof. H. David Rosenbloom the globalization of trade and investment flows is having a profound effect on the practices and policies of international taxation. To meet the needs of lawyers in an interrelated world, law schools must move beyond traditional programs. The ITP offers the largest and most varied selection of international tax courses available at any US law school, including basic and advanced courses in US international taxation, tax treaties, international tax policy, tax planning for cross-broader transactions, comparative international tax policy, and advanced corporate international tax problems. Highly-skilled Brazilian professionals have come to account for one of the greatest communities in this distinguished program, which has a long-standing tradition of academic excellence indeed, Brazilian alumni account for more than 50 graduates throughout the existence of the ITP. This book now brings together 33 of these graduates to analyze complex and current topics of interest in the realm of international taxation. Such topics cover an array of relevant subject matters that vary from policy considerations on the taxation of artificial intelligence to fiscal policy analysis relating to climate change; from the impacts of the US anti-deferral rules on Brazilian oreign structures to the impacts of the US (semi-)territorial regime to multinationals investing in Brazil; from the US limitations on the deductibility of interest to the Brazilian limitations on outbound royalty payments; from a comparative study of the US and the Brazilian worldwide income tax systems to the world trends on digital services taxes; among others. These selected Brazilian ITP alumni take this opportunity, when Prof.