¹ Pires, Manuel, International Juridical Double Taxation of Income (Boston/Dordrecht/London: Kluwer, 1989Google Scholar), chap. 6.

² Taxes are also levied for other reasons, e.g., to correct for externalities or to stabilize the economyGoogle Scholar.

³ The distinction between redistributive and benefit taxes may not be as clear. One could also argue that at least some redistributive taxes could be understood as benefit taxes in the sense that wealthy individuals pay them for the benefits (e.g., lower crime rates, a better-educated workforce) that more egalitarian societies provideGoogle Scholar.

⁴ Biehl, Dieter, “A Taxonomy of International Taxation Principles,” Public Finance 2 (1982), pp. 189–205Google Scholar.

⁵ Knechtle, Arnold A., Basic Problems in International Fiscal Law (Boston/Dordrecht/London: Kluwer 1979), p. 35Google Scholar.

⁶ Biehl, , “A Taxonomy of International Taxation Principles,” p. 190Google Scholar.

⁷ The establishment of such tax treaties gained momentum after 1963 when the Organization for Economic Co-operation and Development (OECD) developed a model tax convention. Most tax treaties follow the structure of this convention. There are today in excess of 1,600 such treaties, and most of these are closely based upon the OECD model and its revised versions. In 1980 the UN published its own model adapted to meet the needs of developing countriesGoogle Scholar.

⁸ These principles only provide a limitation of the conceivable connecting factors, and such limiting factors do not necessarily prevent international double taxation. Even when such limitations on the connecting factors exist, there might still be more than one jurisdiction with such connecting factorsGoogle Scholar.

⁹ These are principles for taxation of income. Analogous principles for commodity taxation are the principle of destination (i.e., the country that imports a commodity has the right to tax it) and the principle of origin (i.e., the country that exports the commodity has the right to tax it). See Biehl, “A Taxonomy of International Taxation Principles,” for a general taxonomyGoogle Scholar.

¹⁰ When both countries are permitted to tax, the country of residence generally provides relief against double taxation. This can be done either by granting a credit for taxes paid in the country of source, or by granting an exemption for taxes on income that has been taxed in the country of sourceGoogle Scholar.

¹¹ For an overview, see Frenkel, Jacob A., Razin, Assaf, and Sadka, Efraim, International Taxation in an Integrated World (Cambridge: MIT Press, 1991Google Scholar).

¹² This is because the source principle assures that the after-tax return to capital is the same in all countries, while the residence principle assures that the pretax return to capital is equalizedGoogle Scholar.

¹³ See, for example, Musgrave, Peggy and Musgrave, Richard, “Inter-Nation Equity,” in Bird, Richard M. and Head, John G., eds., Modern Fiscal Issues (Toronto: Toronto University Press, 1972), pp. 43–63Google Scholar; and Cappelen, Alexander W., “National and International Distributive Justice in Bilateral Tax Treaties,” Finanzarchiv 56 (1999), pp. 424–42Google Scholar.

¹⁴ We use the term “special duties” in a broad sense, so as to include obligations that derive from voluntary agreements or contractsGoogle Scholar.

¹⁵ Hume, David, Enquiries Concerning Human Understanding (New York: Oxford University Press, 1986), pp. 145–53Google Scholar; Rawls, John, A Theory of Justice (New York: Oxford University Press, 1971), pp. 126–30Google Scholar; and Gauthier, David, Morals by Agreement (London: Clarendon Press, 1985), pp. 10–14Google Scholar.

¹⁶ Rawls, , A Theory of Justice, p. 126Google Scholar.

¹⁷ Some writers argue that citizenship should be viewed as a cooperative enterprise for mutual benefit, but it is hard to see how this could be the case in the absence of these types of interactionGoogle Scholar.

¹⁸ This possibility is particularly important in situations where so-called brain drain is a problem or when migration patterns are systematically related to different life stages, known as lifetime migration. These phenomena might undermine the possibility of financing public goods, such as health care and education, given this feature of international fiscal lawGoogle Scholar.

¹⁹ Miller, David, “The Ethical Significance of Nationality,” Ethics 98, No. 4 (1988), p. 648CrossRefGoogle Scholar.

²⁰ Most communitarians would accept that there exist moral constraints on our behavior with respect to persons outside our group, but maintain that these are of a different or less extensive kind than those toward members of our communityGoogle Scholar.

²¹ What constitutes permanently leaving a country may vary. Often the criteria for residence are such that a person is considered a resident in two countries at the same timeGoogle Scholar.

²² It has been argued that the so-called Lockean proviso, important in the derivation of property rights in some traditions, implies some distributive obligations irrespective of any voluntary agreement, but I shall not consider this argument hereGoogle Scholar.

²³ Nozick, Robert, Anarchy, State, and Utopia (New York: Basic Books, 1977), p. 320Google Scholar.

²⁴ This argument would then support the widely held view that taxation without representation is illegitimateGoogle Scholar.

²⁵ Beitz, Charles R., “Justice and International Relations,” Philosophy & Public Affairs 4, no. 4 (1975), pp. 360–89Google Scholar; Beitz, , Political Theory and International Relations (Princeton: Princeton University Press, 1979)Google Scholar; Pogge, Thomas W., Realizing Rawls (Ithaca: Cornell University Press, 1989Google Scholar); and Pogge, , “An Egalitarian Law of Peoples,” Philosophy & Public Affairs 23, no. 3 (1994), pp. 195–224CrossRefGoogle Scholar.

²⁶ See Beitz, , Political Theory and International RelationsGoogle Scholar.

²⁷ Nozick, , Anarchy, State, and Utopia, pp. 320–23Google Scholar.

²⁸ Consequentialists such as Peter Singer and Robert Goodin embrace the assignment approach. Some variants of the entitlement approach, such as those proposed by Beitz and Pogge, might justify equally extensive duties since they argue that we have a morally relevant relationship to all individuals due to interdependence or shared institutionsGoogle Scholar.

²⁹ Goodin, Robert E., “What Is So Special About Our Fellow Countrymen?” Ethics 98, no. 4 (1988), p. 678CrossRefGoogle Scholar.

³⁰ See Goodin, , “What Is So Special About Our Fellow Countrymen?”Google ScholarGoodin, and, Utilitarianism as a Public Philosophy (New York: Cambridge University Press, 1995CrossRefGoogle Scholar).

³¹ Goodin, , Utilitarianism as a Public Philosophy, p. 282Google Scholar.

³² See Shue, Henry, “Mediating Duties,” Ethics 98, no. 4 (1988), pp. 687–704CrossRefGoogle Scholar.

³³ See Alexander W. Cappelen, “Redistribution and the Size of Jurisdictions” (discussion paper presented at the Norwegian School of Economics and Business Administration, November 2000)Google Scholar.

³⁴ See Scheffler, Samuel, “Families, Nations, and Strangers”Google Scholar (the Lindley Lecture, given at the University of Kansas, 1994); and Scheffler, Samuel, “Relationships and Responsibility,” Philosophy & Public Affairs 26, no. 3 (1997), pp. 189–209CrossRefGoogle Scholar.

³⁵ Goodin, , “What Is So Special About Our Fellow Countrymen?” p. 685Google Scholar.

³⁶ See Cappelen, , “National and International Distributive Justice in Bilateral Tax Treaties.”Google Scholar

³⁷ See Pogge, Thomas W., “A Global Resources Dividend,” in Crocker, David A. and Linden, Toby, eds., The Ethics of Consumption: The Good Life, Justice, and Global Stewardship (New York: Rowman & Littlefield, 1998Google Scholar); and Tobin, James, “A Currency Transactions Tax, Why and How,” Open Economies Review 7 (1996), pp. 493–99CrossRefGoogle Scholar.

³⁸ See Cappelen, , “National and International Distributive Justice in Bilateral Tax Treaties.”Google Scholar

³⁹ See Brennan, Geoffrey and Buchanan, James W., The Power to Tax: Analytical Foundations of a Fiscal Constitution (New York: Cambridge University Press, 1980Google Scholar).