Setting Aside International Nexus: Have Taxing Jurisdictions Been Preoccupied with Whether or Not They Could, Without Stopping to Think If They Should?

Tax attorney Joshua Odintz will participate in The University of Chicago Law School's Federal Tax Conference in a panel exploring the international nexus. Under this concept, a jurisdiction may claim the right to tax income, and it has enjoyed a long period of consensus and stability. During this presentation, speakers will explain the origins of the international nexus and its expression in U.S. federal income tax law as well as international income tax treaties. The session will also examine deviations from the international nexus principles, such as the United Kingdom's diverted profits tax (DPT), and conclude with a discussion of whether an adjustment to this concept is needed, given changes in international sentiment and circumstance.