Todd Welty, Mark Thomas, Laura Gavioli and Cym Lowell wrote this bylined article about how new international tax enforcement policies “undermine predictability for all stakeholders, creating serious risks for all parties” by creating double taxation for multinational enterprises (MNEs). “The predictability of tax base results is a serious concern for countries and MNEs alike,” the authors wrote, adding that “the only realistic solution is to design a dependable and independent treaty-based dispute resolution process that accommodates the needs of all stakeholders.”