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 TAX, INEQUALITY,
AND HUMAN RIGHTS
 TAX, INEQUALITY,
AND
HUMAN RIGHTS

Edited by Philip Alston

AND

Nikki Reisch

Tax, Inequality, and Human Rights. Philip Alston and Nikki Reisch.
© Oxford University Press 2019. Published 2019 by Oxford University Press.
 1
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Library of Congress Cataloging-​in-​Publication Data

Names: Alston, Philip, editor. | Reisch, Nikki, editor.
Title: Tax, inequality, and human rights / ​Philip Alston and Nikki Reisch, editors.
Description: New York: Oxford University Press, 2019. | Includes bibliographical references and index.
Identifiers: LCCN 2018038170 | ISBN 9780190882228 ((hardback) : alk. paper) |
ISBN 9780190882235 ((pbk.) : alk. paper)
Subjects: LCSH: Taxation—​Law and legislation. | Tax administration and procedure. | Equality before
the law. | Taxation—​Social aspects. | Tax evasion. | Tax protests and appeals. | Human rights.
Classification: LCC K4460 .T39 2019 | DDC 343.04—​dc23
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 CONTENTS

Foreword ix
Winnie Byanyima, Executive Director, Oxfam International
Acknowledgments xv
Notes on Contributing Authors xvii

Introduction: Fiscal Policy as Human Rights Policy 1

Philip Alston and Nikki Reisch (editors)

PART 1
THE RELEVANCE OF HUMAN RIGHTS TO TAX LAW, POLICY,
AND PRACTICE
1. Taxation and Human Rights: Mapping the Landscape 33
Nikki Reisch
2. Taxing for the Realization of Economic, Social, and Cultural Rights 59
Olivier De Schutter
3. Taxation as a Human Rights Issue: Gender and Substantive Equality 81
Sandra Fredman
4. Tax and Human Rights: The Moral Valence of Entitlements to Tax, Sovereignty,
and Collectives 99
Mitchell A. Kane
5. The Search for Human Rights in Tax 115
Allison Christians
vi  Contents

PART 2
TAX ABUSE IN GLOBAL PERSPECTIVE: CROSS-​B ORDER
DIMENSIONS AND INTERNATIONAL RESPONSES
6. Procuring Profit Shifting: The State Role in Tax Avoidance 137
Alex Cobham
7. A Strange Alchemy: Embedding Human Rights in Tax Policy Spillover
Assessments 161
Nicholas Lusiani and Mary Cosgrove
8. Tax Abuse and Implications for Human Rights in Africa 189
Annet Wanyana Oguttu and Monica Iyer
9. Some Aspects of the Architecture of International Tax Reform (and Their Human
Rights–​Related Consequences) 209
Michael Lennard

PART 3
THE RESPONSIBILITIES OF GOVERNMENTS: THE CASE OF
TRANSPARENCY
10. Transparency, Tax, and Human Rights 237
Miranda Stewart
11. Taxation and Human Rights: A Delicate Balance 259
Reuven S. Avi-​Yonah and Gianluca Mazzoni
12. Corporate Tax Privacy and Human Rights 279
Joshua D. Blank
13. How Countries Should Share Tax Information 303
Arthur J. Cockfield
14. United States’ Responsibility to Promote Financial Transparency 323
Tracy A. Kaye

PART 4
PRIVATE ACTORS AND THE PUBLIC PURSE: THE ROLES OF
CORPORATIONS, LAWYERS, AND ACCOUNTANTS IN TAX ABUSE
15. Interrogating the Relationship between “Legally Defensible”Tax Planning and
Social Justice 347
Daniel Shaviro
 Contents   
vii

16. Who’s to Blame for the Money Drain? Corporate Power and Corruption as
Competing Narratives for Lost Resources 367
Matti Ylönen
17. Creating a Human Rights Framework for Mapping and Addressing Corporate Tax
Abuses 385
Matti Kohonen, Radhika Sarin, Troels Boerrild, and Ewan Livingston
18. ECHR Litigation as a Tool for Tax Justice in Europe 409
Céline Braumann

PART 5
TAXING EQUALITY: NATIONAL DEBATES
19. “Taxing for Growth” vs.“Taxing for Equality”—​Using Human Rights to Combat
Gender Inequalities, Poverty, and Income Inequalities in Fiscal Laws 429
Kathleen A. Lahey
20. Human Rights and the Taxation of Menstrual Hygiene Products in an Unequal
World 449
Bridget J. Crawford and Carla Spivack
21. Recent Cases of Regressive and Racially Disparate Taxation in the United
States 469
Andre L. Smith
22. Labor, Capital, and Human Rights 487
Beverly Moran

PART 6
BRINGING FISCAL POLICY AND SOCIAL RIGHTS TOGETHER
23. Inequality, Taxation, and Public Transfers in Latin America 515
Michael Hanni and Ricardo Martner
24. Basic Income as a Human Right? 541
Daniel J. Hemel
25. Taxation, Human Rights, and a Universal Basic Income 553
Philip Alston

Index 565
 FOREWORD

Wi n n i e Bya ny i m a, Exe c uti ve Director, Oxfam Inter national *

I
nequality, the global economy, and human rights—​and the connections between them—​lie
at the center of one of the most important political debates of our time. And that debate is
increasingly focused on the issue of taxation.
When people hear about tax avoidance and evasion they do not necessarily think of
human rights abuses. To most people, the term “human rights abuses” evokes wrongful impris-
onment, torture, freedom of speech being curtailed. It is time we widened the definition. The
wealthy corporations and individuals sidestepping their obligations to pay tax are human rights
abusers. Every school that is not built, every medicine that is not bought for lack of government
funds due to tax dodging represents an abuse of the rights of women, children, and men across
the world.
As we have learned from many of the greatest social movements in history, it is only when
the moral compass of society shifts that we secure lasting change. We need to make tax dodging
a moral issue—​an issue of human rights. We need to see tax dodging and those who facilitate it
as morally wrong, and the language and laws of human rights can help us achieve this.
There is a growing movement of people, all over the world, who want to ensure every in-
dividual and every corporation pays their fair share of taxes, who fight inequality and support
human rights for all. This movement includes community leaders, activists, academics, writers,
lawyers, students, artists, poets, and economists. It has a rich history. It exists in every country,
from the richest to the poorest. The contributors to this important volume are part of that
movement.

* This foreword is adapted from the keynote address that Ms. Byanyima gave at a conference on Human
Rights and Tax in an Unequal World, held at New York University School of Law in September 2016.
x  Foreword

O xfam has always had human rights at its heart, and because of that, tax justice has become
a greater area of focus in recent years. We know that without tax justice it is impossible to
achieve our vision of a just world without poverty.
The Sustainable Development Goals (SDGs), agreed by the governments of the world in
New York in 2015, set out an ambitious agenda for ending extreme poverty and hunger, ensuring
equal rights for women and for marginalized communities, and much more. Delivering on these
goals will cost trillions of dollars.
We know that aid will remain important for many countries for a long time to come—​
especially for fragile and conflict-​affected states. But aid alone will not suffice. We will only
achieve the SDGs if governments in poorer countries are able to mobilize their own resources,
and then be held to account by their own citizens to spend those resources in a way that benefits
everyone. The SDGs are achievable. The world has enough resources. The problem is that these
resources are shared so unevenly: 1 percent of the people on the planet own the same amount
of wealth as the other 99 percent combined. Oxfam’s analysis in January 2019 showed that just
twenty-​six billionaires own as much same wealth as the poorest half of humanity—​that’s 3.8
billion people.
Faced with such extreme inequality, we must strive for tax justice, both for the revenues that
can be generated and because of the urgent need to redistribute wealth—​and power—​from the
haves to the have-​nots. National tax systems must be judged on how effectively they generate
revenue and how fairly they redistribute wealth, tackle inequalities, and enable people to claim
their human rights. And the global tax system must be judged on whether it makes this possible.
Clement Attlee, the British Prime Minister who introduced the modern welfare state and
the National Health Service in the United Kingdom, said: “Charity is a cold grey loveless thing.
If a rich man wants to help the poor, he should pay his taxes gladly, not dole out money at a
whim.” Tax is the most dignified, reliable, and accountable way of ensuring we can fund the
fulfillment of human rights for all. It is tax that should pay for the things we can only deliver
as a society together—​be it education, health services, energy infrastructure, or roads. These
are not matters of charity! They are rights, and the provision of them is a duty of government
and society.
The rallying call that helped spark the US War of Independence, “No taxation without rep-
resentation,” today seems to have been turned on its head: many of the world’s wealthiest people
and biggest corporations pay little or no tax, while using their wealth to exert huge influence
over political decision-​making, creating rules and systems that work in their favor at the ex-
pense of everybody else.
This capture and distortion of our tax system by wealthy elites is a direct attack on the prin-
ciple of accountable, democratic government. The most fundamental duty of a government
is to ensure the protection and fulfillment of its citizens’ human rights. Through doing so,
governments earn the legitimacy to raise taxes. This is the social contract upon which strong
societies that respect human rights must be built. But this social contract is in danger of falling
apart, unless we boldly reform how tax works at a global level and, for most countries, at a na-
tional level, too.
When governments bow to pressure from powerful corporate interests, and create regressive
fiscal systems that work for the few at the expense of the many, they are fueling political, social,
and economic inequalities, and they are failing in their moral and legal responsibility to protect
their citizens’ human rights.
Even more worryingly, governments across the world are not just favoring the interests of
corporations and wealthy elites, but actively suppressing the voices of civil society actors who
want to hold their governments and the private sector to account. Recently, CIVICUS World
 Foreword   
xi

Alliance for Citizen Participation identified serious threats to civil society in over one hundred
countries—​a figure that is on the rise in recent years. All human rights actors should be con-
cerned by this.

T he global tax system does not need just minor tweaks. It needs a courageous and transforma-
tional overhaul. The forces that have been allowed to shape it until now must be challenged
as we seek to create a better, fairer tax system.
Firstly, we must remind ourselves that the global tax system is a symptom and a cause of a
global economy that is working for a wealthy, powerful elite, at the expense of the many. In the
past few decades, we have seen income and wealth inequality spiral out of control as some top
corporate executives take home ever more obscene pay packets, while millions of workers are
paid poverty wages. We have seen companies successfully lobby governments to reduce regula-
tory controls on labor rights, wages, and environmental standards. And we have seen a corpo-
rate culture develop which prioritizes shareholder returns over all else.
In the United Kingdom, for example, as the Chief Economist of the Bank of England has
stated,1 the average large company was paying out 10 percent of its profits as shareholder
dividends in 1970. Now, that figure has risen to 70 percent. That is money that could be used to
increase innovation or productivity, or to improve wages for ordinary workers, helping ordinary
people. Instead, it is going into the pockets of mostly rich investors.
At the same time, we have seen the use of tax havens skyrocket, to the extent that the
Cayman Islands can receive some 24,000 times more investment per capita than Brazil does. We
have seen levels of inward investments to the British Virgin Islands of more than 66,000 percent
of their GDP. The architecture of tax havens has a pervasive role in causing regressive tax and
spending systems in poor countries. The international tax system encourages harmful tax com-
petition at every level—​and it drives the race to the bottom in corporate taxation.
Many countries have slashed their corporate and high marginal tax rates. The United
States has recently slashed its federal corporate tax rates from 35 percent to 21 percent. We are
witnessing the same trend in Europe over a longer period—​most countries have reduced their
corporate income tax rates—​as well as in emerging or developing countries. The global average
rate for corporate income tax has been falling since the early 2000s from 30 percent to close to
24 percent.
And many governments, especially in poorer countries, are being blackmailed into giving
companies ludicrously generous tax breaks and incentives. Dr. Donald Kaberuka, then President
of the African Development Bank, reflecting on his time as finance minister of Rwanda,
recounted what it felt like to be on the receiving end of tax negotiations: “The multinational
comes to you and says we want to invest in your country, but we need a 5 year tax holiday and
this long list of requirements. And by the way, we only have 6 hours, and then our plane is taking
us to your neighbor, who will probably agree to all of our demands.”
When companies do not pay, governments are left with two basic choices: either they cut
back on services—​something that necessarily erodes the rights of the poorest most, hitting
women and girls particularly hard—​or they shift the burden onto more regressive taxes, such
as value-​added tax (VAT), which fall disproportionately on poor people. In sub-​Saharan Africa,
such indirect taxes make up on average 67 percent of tax revenues.2
There are two primary, interconnected causes of these alarming trends. Firstly, there is the
rise of an economic consensus that took hold in the United States and the United Kingdom in
the early 1980s and then rapidly spread across the world. Neoliberalism has long presented itself
as the only credible economic orthodoxy in town. It is an ideology that promotes the individual
xii  Foreword

above society, that argues for lower taxes and fewer regulations, that downplays any real sense
of corporate social responsibility, and that makes greed not just permissible, but praiseworthy.
There is growing recognition, however, that neoliberalism has been a false prophet. A 2016
report entitled “Neo-​liberalism—​Oversold?” showed how and why the ideology has failed.3 It
showed that deregulating capital movement and slashing public spending has increased ine-
quality, and harmed the level and sustainability of growth that countries could otherwise have
achieved. This wasn’t an Oxfam report. This came from those famous radicals at the International
Monetary Fund!
Second, there is, as I have touched upon, the capture of political and economic systems by
wealthy elites. The fact that those with money can use it to exert influence over decision makers
creates a vicious circle. More wealth leads to more power, which in turn allows the wealthy to rig
the rules so they can accrue even more wealth, leaving everyone else far behind.
Tax rules are a powerful example of this. Grassroots activists and campaigners must contend
with what feels like an army of accountants and lawyers, who are employed to help the world’s
most powerful companies and individuals avoid paying their fair share. Imagine if we were
employing thousands of people in Wall Street to travel around the United States and developing
countries and actually physically destroy public buildings, schools, hospitals, or sack teachers
and nurses. There would be an outcry—​and people would say they are violating the human
rights of those affected.
Yet that is what is effectively taking place every day in these tall glass towers full of dili-
gent accountants, lawyers, and bankers. It is shameful. According to the Centre for Responsive
Politics, the two issues that US policymakers are lobbied on most are the federal budget and
appropriations, and taxes. Oxfam’s report, “Rigged Reform,” showed how the fifty biggest US
companies—​including global brands such Pfizer, Goldman Sachs, Walmart, and Apple—​have
stashed about $1.6 trillion dollars offshore.4 The same fifty companies spent $2.5 billion lobbying
the US government between 2009 and 2015. An estimated $352 million was spent lobbying on
tax issues—​helping to secure over $423 billion in tax breaks. So for every $1 spent on lobbying,
these fifty companies collectively received an estimated $1,200 in tax breaks. That is a scan-
dalous rate of return.
If the causes of our broken tax system are not unique to tax, then our solutions will not be
either. Power and accountability must be central to both our concept of tax justice and to the
human rights framework. That focus demands we take a critical look at who is currently making
the rules. The global tax system has insufficiently evolved over many decades. Some of the un-
derlying principles remain stuck in the past, with rules that might have worked in the 1920s but
which bear little relevance in the globalized economy that we have today. Fixing this anachro-
nistic and tangled system will take coordinated, ambitious action from the world’s governments.
We can take some encouragement from the fact that there have been more attempts in recent
years to start to get to grips with this.
The G20 and the OECD did recognize that something had to be done about corporate tax
avoidance in particular. The so-​called Base Erosion and Profit Shifting (BEPS) process that they
initiated has taken some welcome steps in the right direction, improving the sharing of infor-
mation between tax authorities, for example. These steps do not go nearly far enough, however,
particularly in addressing the needs of developing countries. That is hardly surprising as a ma-
jority of developing countries—​representing two-​thirds of the world’s governments—​had no
formal role in the negotiating process.
Many issues that are priorities for developing countries are still not addressed. For example,
BEPS does not address the challenge of knowing whether the price of a good or service “traded”
between different parts of the same global company is fair, or how to analyze and tackle harmful
 Foreword   
xiii

tax incentives. Developing countries would also like to see a greater focus on preventing tax
avoidance through more systemic actions, whether broader agreement on anti-​abuse rules or
on new ways to tax multinationals in the twenty-​first century.
We want to see steps taken toward the creation of an inclusive, accountable multilateral tax
body, in which all countries have an equal seat at the table—​something that Oxfam and others
have long been calling for. Based upon the existing legal responsibilities that all states have to
achieve full human rights, this new body should also be empowered to sanction governments
whose policies are harming the ability of other countries to raise the revenue that they need to
fulfill the rights of their own populations. It should require all states to undertake assessments
of the human rights implications of their tax policies, within their own borders and for other
countries. The United Nations must have a central role to play in this process, facilitating inclu-
sive intergovernmental negotiations, ensuring that the voices of rich countries aren’t allowed to
dominate, and bringing in the private sector, civil society, and other multilateral institutions.
Even if progressive tax systems are agreed upon, ensuring that they actually work in prac-
tice represents a significant further challenge. That is where transparency comes in. Citizens—​
and governments—​must be able to know how money is flowing within and across borders and
where tax should be levied but is actually being avoided and evaded. A number of potential
measures would be both powerful and pragmatic; technical but transformative. For example,
multinational companies must be required to report publicly on their turnover, profits, and
taxes in every country where they operate.
Similarly, we know that many rich individuals are using tax havens to hide their wealth
or as bases from which to make investments, often through opaque layers of companies. The
public has a right to know who really is behind these shell companies. The Panama Papers
and the Paradise Papers had a powerful effect in raising global attention to this—​and people
around the world responded angrily. There is growing pressure for every country to establish
public registries of beneficial ownership for all companies, trusts, and partnerships held there.
It has been encouraging to see a wide range of countries commit to such public registries for
companies within recent years, including the United Kingdom, France, Kenya, Nigeria, and
Afghanistan. The European Union has made a similar commitment requiring public registers
for companies. The United Kingdom will now require its overseas territories to publish public
registers for companies.
Automatic exchange of information between revenue authorities will also help, though we
must avoid insisting on full reciprocity if one country simply does not have the resources or
capacity to provide as much information as another. Otherwise, we again risk disadvantaging
poorer countries.
State capacity is critical. Governments and their revenue authorities, especially in poorer
countries, have the odds stacked against them when they are up against the armies of tax lawyers
and accountants employed by major tax dodgers. Sub-​Saharan African countries would need to
employ more than an estimated 650,000 additional tax officials for the region to have the same
ratio of tax officials to population as the OECD average. So governments in poorer countries
must invest in building up effective tax revenue authorities to collect the taxes that are due and
to clamp down on abuses of the system. They must be supported in this endeavor, with sufficient
resources and with the ability to impose meaningful sanctions on those who commit or facilitate
tax dodging.
It has been in the interests of tax dodgers, and those who facilitate tax dodging, to make
sure that tax laws are as complex and opaque as possible. It is essential that we find ways to de-
mystify tax—​to get people to see that their rights are at stake, and to show them that there is
something they can do about it. Tax justice can only be achieved when citizens are able to make
xiv  Foreword

their voices heard at all stages of the process and can hold their governments to account on both
policymaking and implementation.
Human rights frameworks give us further opportunities to hold governments and
corporations to account. For example, governments who are not doing all they can to generate
resources for essential public services, and who are thus failing to meet the economic and social
rights of their citizens, could be challenged in national courts or through international fora such
as the Human Rights Council.
The same can apply to corporations too. Tax behavior should be assessed alongside
companies’ other commitments to sustainable development under, for example, the UN Global
Compact initiative, and should be seen as relevant to a company’s “corporate responsibility to
respect human rights” outlined in the UN Guiding Principles for Business and Human Rights.
Well-​designed tax systems that redistribute wealth and drive spending on public goods are
one of the best weapons we have in the fight against inequality and poverty. Badly designed tax
systems, on the other hand, exacerbate both. When judging efforts at a national level, therefore,
we must ask whether or not tax reforms will serve to reduce inequalities while raising enough
money to fulfill the rights and needs of their citizens. We must look at whether countries are set-
ting progressive marginal tax rates, at whether they are relying more on direct or indirect taxes,
at whether they are implementing wealth and inheritance taxes, at their corporate tax rate and
the effective incidence of this.
And when assessing efforts to reform tax at a global level, we must ask ourselves whether or
not the reforms are making it easier for national governments to implement these kinds of pro-
gressive, effective tax systems within their own countries, or will they still find themselves at the
mercy of the big multinationals and the global super-​rich?

C reating a fairer tax system continues to be an uphill battle. But there are reasons for opti-
mism. After multiple high-​profile tax scandals, and as ordinary citizens around the world are
feeling the impact of an economic system that is rigged against them, governments are under
pressure to act and have taken some steps in the right direction. Lasting change will occur, I be-
lieve, when we make tax dodging and those who facilitate it morally unacceptable. Let us expose
more than ever how tackling tax dodging is fundamental to realizing and respecting the human
rights of people all over the world, and vital to ending the injustice of poverty.

NOTES
1. D. Weldon, ‘Shareholder power “holding back economic growth” ’, BBC News, 24 July 2015, avail-
able online at https://​www.bbc.com/​news/​business-​33660426.
2. IMF, Fiscal Policy and Income Inequality, IMF Policy Paper (2014), at Figure 8, available online at
https://​www.imf.org/​external/​np/​pp/​eng/​2014/​012314.pdf.
3. J. D. Ostry, P. Loungani, and D. Furceri, IMF, ‘Neoliberalism: Oversold?’, Finance & Development
(2016), available online at https://​www.imf.org/​external/​pubs/​ft/​fandd/​2016/​06/​pdf/​ostry.pdf.
4. Oxfam, Rigged Reform (2017), available online at https://​www.oxfamamerica.org/​static/​media/​
files/​Rigged_​Reform_​FINAL.pdf.
 ACKNOWLEDGMENTS

T
he co-​editors are very grateful to the many people who contributed to planning, running,
and participating in the conference that generated the chapters in this volume. The con-
ference was organized by the Center for Human Rights and Global Justice at New York
University School of Law, and particular thanks are due to Lauren Flanagan, Pamela
Mercado, Nealofar Panjshiri, Deborah Popowski, Silvia de Rosa, and Anam Salem.
We received very helpful advice in relation to topics and speakers from our colleagues in
the NYU School of Law Tax Program, and especially from Daniel Shaviro and Mitchell Kane.
Allison Christians and Krishen Mehta also provided important insights.
The conference was followed by a workshop on legal accountability for tax injustice, which
involved a range of advocates, practitioners, and scholars from around the world. We are
grateful to the Open Society Foundations, and their Public Health Program, Fiscal Governance
Program, and the Open Society Justice Initiative, for financial and logistical support for the
workshop, as well as their participation in its conceptualization. Thanks are due to Betsy Apple,
Ben Batros, Reema Hijazi, Rosalind McKenna, and Vera Mshana.
Other groups working on issues relating to taxation and human rights also provided valu-
able advice and assistance in the context of both the conference and the workshop. In particular,
we are grateful to the staff of the Center for Economic and Social Rights, especially Niko Lusiani,
and to the staff of Tax Justice Network, especially Alex Cobham and Liz Nelson.
We are also grateful to Jessye Freeman for assistance in editing the manuscript, and to Blake
Ratcliff and his colleagues at Oxford University Press.
 NOTES ON CONTRIBUTING AUTHORS

Philip Alston is John Norton Pomeroy Professor of Law at New York University School of Law
and is also currently UN Special Rapporteur on extreme poverty and human rights.
Reuven S. Avi-​Yonah is the Irwin I. Cohn Professor of Law and director of the International Tax
LLM Program at the University of Michigan Law School. He specializes in corporate and inter-
national taxation. He has served as a consultant to the US Department of the Treasury and the
Organisation for Economic Co-​operation and Development (OECD) on tax competition, and is
a member of the steering group for OECD’s International Network for Tax Research.
Joshua D. Blank is Professor of Law at the University of California, Irvine School of Law. He pre-
viously taught at New York University School of Law, where he was Professor of Tax Law, Vice
Dean for Technology-​Enhanced Education, and Faculty Director of the Graduate Tax Program.
His scholarship focuses on tax administration and compliance, taxpayer privacy and tax trans-
parency, and taxation of business entities.
Troels Boerrild is Head of Responsible Investments at Danish Pension fund, MP Pension. At the
time of writing he was Senior Policy and Advocacy Adviser at ActionAid Denmark.
Céline Braumann is a Lecturer and Researcher in the Department of European, International,
and Comparative Law at the University of Vienna. She holds an LLM from New York University
School of Law, and her research focuses on international economic law and the effects of and
remedies for economic and social inequality and injustice.
Winnie Byanyima is Executive Director of Oxfam International. She is a global women’s rights
leader, human rights defender and a global authority on economic inequality. She served eleven
years in the Ugandan Parliament, and has served at the African Union Commission and as
Director of Gender and Development at the UN Development Program.
Allison Christians is the H. Heward Stikeman Chair in the Law of Taxationat McGill University
Faculty of Law, where she teaches and writes on national, comparative, and international tax law
and policy.
Alex Cobham is chief executive of the Tax Justice Network, and a founding member of the
steering group of the Independent Commission for the Reform of International Corporate
xviii  Notes on Contributing Authors

Taxation (ICRICT). Previously he was a research fellow at the Center for Global Development,
and before that held posts at Christian Aid, Save the Children, and Oxford University (St Anne’s
College and Queen Elizabeth House).
Arthur J. Cockfield is a Professor at Queen’s University Faculty of Law, where he was appointed
as a Queen’s National Scholar. He is a senior research fellow at Monash University, and has been
a Fulbright Visiting Chair in Policy Studies at the University of Texas at Austin. His research
mainly focuses on tax law.
Mary Cosgrove is a lecturer on tax and accountancy at the J.E. Cairnes School of Business and
Economics, National University of Ireland, Galway, and a doctoral candidate at the Irish Centre
for Human Rights. She previously worked as a tax adviser for over fifteen years, including in a
“Big Four” accountancy firm and a multinational enterprise.
Bridget J. Crawford is a Professor at the Elisabeth Haub School of Law at Pace University School
of Law. She is a member of the American Law Institute and the American College of Trust and
Estate Counsel, and her most recent book is Feminist Judgments: Rewritten Tax Opinions (with
Anthony C. Infanti).
Olivier De Schutter is a professor at the University of Louvain (Belgium) and at SciencesPo
(France). From 2008 to 2014 he was the UN Special Rapporteur on the right to food, and since
2015, has been a member of the UN Committee on Economic, Social and Cultural Rights.
Sandra Fredman is Professor of Law at the University of Oxford, a Fellow of the British Academy,
and a Queen’s Council (honoris causa). She has published widely in the fields of equality, labor law,
and human rights. In 2012, she founded the Oxford Human Rights Hub, of which she is the director.
Michael Hanni is an Economic Affairs Officer in the Economic Development Division of the
UN Economic Commission for Latin America and the Caribbean (ECLAC).
Daniel J. Hemel is an assistant professor at the University of Chicago Law School, where he
teaches tax, administrative law, and torts. He previously clerked for Judge Michael Boudin on the
US Court of Appeals for the First Circuit, Judge Sri Srinivasan on the US Court of Appeals for
the District of Columbia Circuit, and Associate Justice Elena Kagan on the US Supreme Court.
Monica Iyer is a human rights attorney and consultant based in Milan, Italy. She has worked
on human and civil rights issues for a number of nongovernmental, state, and international
organizations, including the UN Office of the High Commissioner for Human Rights and the
New York State Office of the Attorney General.
Mitchell A. Kane is the Gerald L. Wallace Professor of Taxation at New York University School
of Law. He clerked for the Honorable Karen LeCraft Henderson of the US Court of Appeals for
the DC Circuit and practiced law with the firm of Covington & Burling before joining the fac-
ulty at the University of Virginia School of Law.
Tracy A. Kaye is a Professor of Law and Eric Byrne Research Fellow at Seton Hall Law School.
She specializes in US federal income tax law and international, European Union, and compara-
tive tax law. She has been the Fulbright Senior Research Scholar at the University of Luxembourg,
PwC Visiting Professor at the Vienna University of Economics and Business, and Research
Scholar at the Max Planck Institute for Intellectual Property, Competition, and Tax Law. Prior
to beginning her academic career at Seton Hall Law School, Kaye earned a B.S. in Accountancy,
magna cum laude, at the University of Illinois; an M.S. in Taxation at DePaul University; and her
J.D., cum laude, at the Georgetown University Law Center.
 Notes on Contributing Authors   
xix

Matti Kohonen is Principal Adviser on the Private Sector, at Christian Aid. He worked for over
ten years on the impact of financial and tax policies on developing countries and populations,
and is a founding member of the Tax Justice Network and co-​editor of a volume entitled Tax
Justice: Putting Global Inequality on the Agenda.
Kathleen A. Lahey is Professor and Queen’s National Scholar, Faculty of Law, Queen’s University,
Canada, and specializes in tax law, fiscal policy, and human rights. She was a Visiting Professor
in Fiscal Policy at Umeå University, Sweden, Visiting Scholar at the International Tax Program,
Harvard Law School, and has multijurisdictional expertise in tax, economic laws, and fiscal
policies.
Michael Lennard is Chief of International Tax Cooperation in the Financing for Development
Office of the United Nations. He previously held posts at the Organisation for Economic
Co-​operation and Development (OECD), the Australian Tax Office, and the Australian
Government’s Office of International Law, where he worked on tax, trade, investment, and
human rights issues.
Ewan Livingston is Head of Corporate Partnerships at ActionAid UK, an international charity
that works with women and girls living in poverty. He leads ActionAid’s engagement with the
private sector on issues including tax and human rights.
Nicholas Lusiani is Senior Advisor at Oxfam, focused on tax and inequality. At the time of
writing the article in this volume, he directed the Human Rights in Economic Policy Program at
the Center for Economic and Social Rights. He previously worked in the fields of business and
human rights, external debt, humanitarian relief, indigenous rights in the extractive industry,
and criminal justice.
Ricardo Martner is Chief of the Fiscal Affairs Unit in the Economic Development Division of
the UN Economic Commission for Latin America and the Caribbean (ECLAC), and has worked
with ECLAC since 1986. He has written widely in the field of public finance.
Gianluca Mazzoni is an SJD candidate at the University of Michigan Law School, where he also
completed his LLM degree in International Tax in 2016. He was previously a trainee tax lawyer
in a leading Italian tax law firm. His research is focused on the interaction between the right to
privacy and data protection and tax law.
Beverly Moran is Professor of Law and Professor of Sociology at Vanderbilt University Law
School, where she has taught since 2001. In addition to her work on the Internal Revenue Code,
her interdisciplinary and multidisciplinary work encompasses empirical legal studies, interna-
tional and comparative tax law, Islamic law, labor law, law and development, legal education,
legal philosophy, and politics.
Annet Wanyana Oguttu is a professor of tax law at the University of Pretoria. She has published
extensively on international tax law and is a rated researcher under South Africa’s National
Research Foundation. In 2014, the President of South Africa appointed her as a Commissioner
of the South African Law Reform Commission, and in 2013, she became a member of the Davis
Tax Committee to assess South Africa’s tax policy framework.
Nikki Reisch is the Legal Director of the Center for Human Rights and Global Justice and a
supervising attorney in the Global Justice Clinic at New York University School of Law. She
previously worked as an advocate challenging adverse impacts of international financial and
development institutions on communities in the Global South, and clerked for the Second and
Ninth Circuit Courts of Appeals.
Another random document with
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 THE AMERICAN.
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WHARTON BARKER, Editor.
The American is fighting the battle of the masses against those
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THE AMERICAN,
No. 119 SOUTH FOURTH St., PHILADELPHIA.

Little Journeys
SERIES FOR 1896

Little Journeys to the Homes of

American Authors.
The papers below specified were, with the exception of that
contributed by the editor, Mr. Hubbard, originally issued by the late
G. P. Putnam, in 1853, in a book entitled Homes of American
Authors. It is now nearly half a century since this series (which
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papers of such distinctive biographical interest and literary value.

No. 1, Emerson, by Geo. W. Curtis.

” 2, Bryant, by Caroline M. Kirkland.
” 3, Prescott, by Geo. S. Hillard.
” 4, Lowell, by Charles F. Briggs.
” 5, Simms, by Wm. Cullen Bryant.
” 6, Walt Whitman, by Elbert Hubbard.
” 7, Hawthorne, by Geo. Wm. Curtis.
 ” 8, Audubon, by Parke Godwin.
” 9, Irving, by H. T. Tuckerman.
” 10, Longfellow, by Geo. Wm. Curtis.
” 11, Everett, by Geo. S. Hillard.
” 12, Bancroft, by Geo. W. Greene.

The above papers will form the series of Little Journeys for the
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They will be issued monthly, beginning January, 1896, in the
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G. P. PUTNAM’S SONS,
NEW YORK AND LONDON

Quarterly. Illustrated.

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286 ROXBURY STREET, BOSTON.
 RUSSIAN FAIRY TALES: Translated by R. Nisbit Bain.
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OLD ENGLISH FAIRY TALES: By S. Baring Gould. With
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SHELLEY’S TRANSLATION OF THE BANQUET OF PLATO: A
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HAND AND SOUL: By Dante Gabriel Rossetti. Printed by Mr.
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This book is printed in the “Golden” type, with a specially
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For sale by all booksellers, or mailed postpaid by the publishers,
on receipt of price.
WAY & WILLIAMS,
Monadnock Block. Chicago.

1. RUBAIYAT OF OMAR KHAYYAM.

RENDERED INTO ENGLISH VERSE
BY EDWARD FITZGERALD.
 This is not a mere reprint of “The Bibelot” edition, but has been
edited with a view to making FitzGerald’s wonderful version
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The following are special features that as a whole can only be
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I. An entirely new biographical sketch of Edward FitzGerald by Mr.
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925 copies on Van Gelder’s hand-made paper at $1.00 net.
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Address THOMAS B. MOSHER,

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A SHELF OF BOOKS.

LITTLE JOURNEYS.
 To the Homes of Good Men and Great.
By Elbert Hubbard. Series 1895, handsomely bound. Illustrated
with twelve portraits, etched and in photogravure. 16mo., printed
on deckle-edge paper, gilt top. $1.75.

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NO ENEMY: BUT HIMSELF.

The Romance of a Tramp. By Elbert Hubbard. Twenty-eight full-
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By Maurus Jokai. (The great Hungarian Novelist.) An
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 FOOTLIGHTS,
that weekly illustrated paper published in Philadelphia (pity, isn’t
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THE ROYCROFT PRINTING SHOP,
East Aurora, New York.
 CATHOLICITY IN ART.
All’s one, all’s one! the critic learns,
Though hostile tastes be frowning;
That poets’ flame where Bobby burns,
Where, too, is Robert, browning.

Walter Storrs Bigelow.

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