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Is the UTPR Extraterritorial or Discriminatory?
No full textOn January 20 President Trump issued two executive orders on international tax. The first order rejected the OECD’s two-pillar project, stating: The OECD Global Tax Deal supported under the prior administration not only allows extraterritorial jurisdiction over American income but also limits our Nation’s ability to enact tax policies that serve the interests of American businesses and workers. Because of the Global Tax Deal and other discriminatory foreign tax practices, American companies may face retaliatory international tax regimes if the United States does not comply with foreign tax policy objectives. This memorandum recaptures our Nation’s sovereignty and economic competitiveness by clarifying that the Global Tax Deal has no force or effect in the United States
High Tech Touts
No full textThis essay has three interrelated aims. First, it articulates a set of capacities I call virtues of attention—capacities for intuitive discernment, good judgment about what is worth sustained focus, and the ability to engage deeply with worthwhile things. These are eudaimonist virtues in that they help us live well, not merely act rightly. Second, the essay explores what I call poisonous persuasion: the idea that rhetorical appeals, especially those used in marketing, may not only succeed by appealing to certain desires or habits of mind but may also deepen and entrench them. Third, I bring these insights together to examine a largely neglected problem at the intersection of AI and virtue ethics: how AI-aided marketing may erode the very capacities we need to flourish.
This is not primarily an essay about how AI might itself be made virtuous, nor whether it can mimic or model virtue, though those are important questions. Rather, the focus is on what AI-driven persuasion may be doing to us. The danger is not just distraction, which has been well-documented, but a subtler debilitation: an incremental erosion of the attentional capacities on which flourishing depends. These systems appeal to what works—what clicks, what sells—without regard for what they may be nurturing in us. This paper uses virtue ethics to illuminate this harm: not a spectacular or easily measured injury, but a quiet undermining of our ability to recognize, commit to, and engage with the good. If we hope to thrive rather than merely function, we must understand and resist these corrosive dynamics
How Experts View the Legal System\u27s Use of Scientific Evidence
No full textLegal scholars and courts frequently write about how scientific evidence is vetted and presented in legal proceedings, but the views of experts themselves have received little attention. Our research aims to fill that gap. This paper reports some of what we learned from a series of surveys we conducted, beginning with a survey in 2016 of scientists who had been elected to membership in the American Academy of Arts and Sciences.3 Subsequent surveys were directed to subscribers of the journal Science who identified as scientists and engineers and to self-identified experts who advertised their availability as experts to lawyers or appeared in the expert listings on Westlaw. Responses from those surveyed capture how they regard key actors in the legal system (Judges, Jurors, Lawyers, Other Experts) as well as the weaknesses these experts see in how the legal system treats scientists and handles scientific evidence. We also examine the extent to which expert evaluations of these issues are mediated by their experience in testifying in legal proceedings
US Policy and Pillar 2: The Evolution of US Tax Policy Toward OECD Pillar 2 and Its Global Implications
No full textThis paper analyzes the United States’ evolving position on OECD Pillar 2, focusing on the Trump administration’s initial rejection and subsequent negotiations to exempt US multinationals from the Undertaxed Profits Rule (UTPR). It examines the legislative and diplomatic strategies that led to international acceptance of GILTI as a valid IIR. The analysis concludes that the resulting compromise preserves US tax sovereignty while maintaining the global framework’s integrity
Tribal Legal Licensing of Attorneys, House Counsel Status, and The Opportunity to Redefine the JD Preferred Position and the Entire Lawyer Ecosystem
Full text linkThe recognized right of Indian Tribes to license has been a known reality dating back to the Supreme Court’s ruling in Worcester v. Georgia, 31 U.S. 515 (1832) where state law was found inapplicable on the lands of the Cherokee. However, the modern implications of tribal licensing and regulation have only just begun to be explored in the context of the modern American regulatory system. In fact, the ability of Indian Tribes to license attorneys to practice law within their court systems has largely gone unexamined outside of a few exceptions such as the Tribal Law and Order Act of 2010. In 2022, at Fidelity National Financial, a Fortune 500 Company located in Jacksonville, Florida, the implications of this sovereign power were displayed through my application for “Authorized House Counsel status” in Florida based on my admission to the Bar of the St. Croix Chippewa Indians of Wisconsin, a federally recognized Indian Tribe. After a five-month process with the Florida Bar, I was admitted as house counsel thus providing a case study in the redefining of Indian Tribes as U.S. Jurisdictions of law in the aftermath of the Treaty Era of Indian Affairs. This article will examine the early pioneers of Tribal legal licensing, and the history of Tribes licensing attorneys and advocates in their court system through their sovereignty. This article will also spotlight the incredible opportunity presented for JD preferred position holders and their employers in this underexamined regulatory area. In coordination with house counsel admissions and pro hac vice opportunities, Tribal legal licensing may provide a solution to the attorney shortage in Indian Country and rural areas of the country which has been exacerbated in the aftermath of McGirt
Taking Revolution Seriously
Full text linkA review of Tip of the Spear: Black Radicalism, Prison Repression, and the Long Attica Revolt. By Orisanmi Burton
