Original Sin: Cost Sharing in the United States

David Rosenbloom and Elizabeth Stevens co-authored the article "Original Sin: Cost Sharing in the United States" published in Tax Notes on November 7, 2024. 

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Elizabeth J. Stevens is a member in the international tax practice at Caplin & Drysdale Chtd. in Washington. H. David Rosenbloom is a member with Caplin & Drysdale Chtd. in Washington, the James S. Eustice Visiting Professor of Taxation and director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors.

In this article, the authors provide an overview of how U.S. tax policy enabled multinational enterprises to use cost-sharing arrangements to their disproportionate gain, with still-reverberating consequences for global tax policy.

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