By Atalya Santos | Volume 9 | Issue 1 This Note examines the Internal Revenue Service’s application of § 6662 accuracy-related penalties in transfer pricing disputes, with particular focus on how the agency evaluates the adequacy of contemporaneous transfer pricing documentation prepared by multinational corporations (MNCs). It argues that the United States’ penalty-centered enforcement model reflects an aggressive compliance strategy that diverges meaningfully from the appro

This Note compares the Morrocan-Polisario Front conflict over Western Sahara to the Israeli-Palestinian conflict in hopes of taking the legal lessons from Israel and learning the best path forward for the Western Sahara conflict. Read the full Note here:

By examining the historical precedent and contemporary manifestations of sexual violence in armed conflicts and honing in on the instances of sexual and gender-based violence (SGBV) in Ukraine, this Note elucidates the multifaceted nature of sexual violence as a tool of terror and control, underscores its enduring impact on survivors and communities, and advocates for the state implementation of measures to address and prevent such atrocities. Read the full Note here:

This Note looks to see whether a fiduciary claim similar to the one found in Trevorrow v State of South Australia may be replicated in a Tucker or Indian Tucker Act claim brought by boarding school survivors. Read the full Note here: