MJIL Online

38 MJILDIGTIALSYMPOSIUM 1 On October 13, 2017, tax specialists and international law experts from universities, private practice, and global institutions explored the implications of the recently signed Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The day-long conference was organized at the University of Michigan Law School by Professor Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law and Director of the International Tax LLM Program at
Sara Stappert Vol. 39 Associate Editor June 27, 2017 was a dark day for tech giant Google as European Union (EU) antitrust officials fined the company “a record $2.7 billion for unfairly favoring some of its own services over those of rivals.”[1] The antitrust decision was specifically targeted at Google’s online shopping service. It is alleged that Google promoted Google Shopping in organic search results[2] while simultaneously demoting rival services in 13 of the 31
Gianluca Scaglione Vol. 39 Associate Editor Now more than ever, privacy and its cybersecurity dimension demand increased attention. As digital technology and its uses expand rapidly, the amount of data generated about every individual is staggering: from our real-time movement location to texts and emails, almost everything we do is encapsulated on a daily basis in the devices we use. In the face of rapid technological development—situated as we are at the dawn of the
Peter Liu Vol. 39 Associate Editor China revealed in the 19th Party Congress the new members of the Politburo Standing Committee. This Congress heralds the beginning of President Xi Jinping’s second five-year term. During a president’s first term, the members of this Committee are holdovers from the previous administration, appointed by the outgoing leader. It is during the second term that a president is fully empowered to pursue his own agenda, as he fills the
David Smellie & Zachary Simon Vol. 39 Associate Editors History and Overview of the TPP Signed in February 2016, the Trans-Pacific Partnership (TPP) was meant to be a watershed moment for trade in the Pacific. The twelve signatories to the agreement, all of whom border the Pacific Ocean, collectively account for 40 percent of global GDP and one-third of global trade.[1] The goal of the agreement was straightforward: to strengthen economic ties between Pacific nations
Sara Shea Volume 39 Associate Editor The Rana Plaza building in Bangladesh was home to five garment factories that manufactured goods for European and North American retail companies.[1] In 2013, this eight-story building collapsed, killing more than one-thousand people and injuring thousands more.[2] The building was unfit for the garment industry: the construction’s poor quality and the swampy land it stood on could not withstand the massive, heavy equipment weighing on each of the floors.[3]
Han Zhu Vol. 39 Executive Editor On June 30, 2017, the spokesman of the Chinese Foreign Ministry, in a retort to foreign statements regarding the political conditions of Hong Kong, said the Sino-British Joint Declaration, which laid the groundwork for Hong Kong’s handover, is a “historical document that no longer has any realistic meaning.”[i] Not only did this statement immediately raise concerns about China’s 50-year promise of the so-called “one country, two systems” framework implemented
Cite: Reuven S. Avi-Yonah, Altera, the Arm’s Length Standard, and Customary International Tax Law, 38 MJILOpinioJuris 1 (2017), http://www.mjilonline.org/altera. (PDF) ALTERA, THE ARM’S LENGTH STANDARD, AND CUSTOMARY INTERNATIONAL TAX LAW Reuven S. Avi-Yonah* Irwin I. Cohn Professor of Law, the University of Michigan  Abstract The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issues in regard to the much-debated topic of whether customary international tax law (CITL)
Jessica Riley Vol. 39 Associate Editor They have been called “the world’s most persecuted people.”[1] They have been denied citizenship and basic human rights in the only country many have ever known.[2] They have been beaten, raped, and murdered.[3]  For many of the Rohingya people, this laundry list of abuses has recently reached an alarming crescendo of extreme violence causing more than 600,000 people to flee their homes in the Rakine state in an attempt
Layan Charara Vol. 39 Associate Editor On October 27, 2017, Burundi became the first country to withdraw from the International Criminal Court (ICC).[1] Its withdrawal is presumed to be an attempt to elude scrutiny of the carnage ensuing since President Pierre Nkurunziza made a third bid for the presidency in 2015.[2] The Nkurunziza administration is accused of committing crimes against humanity, including killing, torture, sexual violence, and forced disappearance.[3] Burundi, however, cites the Court’s fixation