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Emory International Law Review Recent Developments

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Fractioning and fairly distributing parts of a whole is never quite straightforward. Whether we speak of justly portioning and dividing scrambled eggs between siblings or jurisdictional claims over the ocean space between nations, reckoning with the dilemmas of sharing is an integral part of the human experience. Acknowledging that, this essay contends that contemporary discussions on fairness in international taxation ought to be situated within this broader context. It is centrally argued that justly allocating taxing entitlements over cross-border wealth is a task contingent on the same subjective predicaments seen in the division process of any given valuable whole. The analysis proceeds by reference to two proposed elements, namely unrestrained perception of value and nature of the divided thing. In conclusion, it is reasoned that, while a strictly objective (often termed scientific) conception of international taxation is unattainable, a less biased version, inspired by double-blind methodology, may be within reach.



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