Journal of Law and Political Economy

In March 1923, a group of prominent political economists and tax law experts gathered in Geneva, Switzerland to discuss the post–World War I framework for a new international tax regime. Commissioned by the League of Nations, these experts produced a comprehensive report that gradually became the intellectual foundation of the modern international tax regime. Relying on archival materials and other primary sources, this article contends that the US expert Edwin R. A. Seligman played a vital role in revising the report. While scholars have noted Seligman’s influence over US tax law and policy, his pivotal role in drafting the 1923 report has only recently been acknowledged. This article builds on this recent scholarship by investigating how Seligman’s background, experiences, and ideas—particularly his analysis and advocacy of the concept of “ability to pay” and “economic allegiance”—shaped the 1923 Report, and hence the subsequent development of the modern international tax regime.