Date of Award

2020

Degree Type

Dissertation

Degree Name

Doctor of Juridical Science (S.J.D.)

First Advisor

Reuven S. Avi-Yonah

Second Advisor

Daniel Halberstam

Third Advisor

Nicola Sartori

Abstract

This dissertation is comprised of the following articles:

  • The Italian Patent Box Regime and the Foreign Tax Credit, published as Mazzoni, G. “The Italian Patent Box Regime and the Foreign Tax Credit.” European Taxation 59, no. 9 (August 20, 2019). https://doi.org/10.59403/2p3evbr.
  • The Italian Supreme Court's Decision in the ITW case (No. 32840): The Beneficial Ownership Requirement and Double Non-Taxation?
  • Present at the Creation: Archival Research and Evidence on the Origins of the Single Tax Principle, published as Mazzoni, Gianluca. “Present at the Creation: Archival Research and Evidence on the Origins of the Single Tax Principle.” Intertax 47, no. Issue 10 (October 1, 2019): 813–31. https://doi.org/10.54648/taxi2019084.
  • A Comparison of the U.S. Economic Substance Doctrine with Italy's New Abuse of Law Rules: Gravitation Towards Similar Outcomes? Published as Mazzoni, G. “A Comparison of the US Economic Substance Doctrine with Italy’s New Abuse of Law Rules: Gravitation towards Similar Outcomes?” Bulletin for International Taxation 73, no. 5 (April 25, 2019). https://doi.org/10.59403/1y0xjv7.
  • (Re)defining the Balance between Tax Transparency and Tax Privacy in the Big Data Analytics. Published as Mazzoni, G. “(Re)Defining the Balance between Tax Transparency and Tax Privacy in Big Data Analytics.” Bulletin for International Taxation 72, no. 11 (October 24, 2018). https://doi.org/10.59403/1za3y9w.
  • Abuse and Aggressive Tax Planning between OECD and EU Initiatives: Between the New Challenges of FATCA and Data Protection

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