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Inversions, Related Party Expenditures, And Source Taxation: Changing The Paradigm For The Taxation Of Foreign And Foreign-Owned Businesses, Julie A. Roin
BYU Law Review
The disconnect between the rules for the taxation of domestic businesses and foreign and foreign-owned businesses operating in the United States both diminishes the federal treasury and distorts taxpayer and business behavior. Yet bringing the sets of rules into closer coordination is no simple task. This Article examines many of the solutions proffered in the academic literature and details the difficulties and trade-offs that each entails.
Thoughts On Treasury's White Paper On Eu State Aid, Jeffrey M. Kadet
Thoughts On Treasury's White Paper On Eu State Aid, Jeffrey M. Kadet
Articles
The U.S. Department of the Treasury on August 24 issued a White Paper that expresses its concerns about the European Commission’s efforts to apply the European Union’s State aid restrictions to multinational enterprises’ profit-shifting structures. This article comments on two aspects of the white paper that are technically correct, but require a little more explanation for readers to understand their significance. These two aspects are:
First, the article clarifies that the general comments that the White Paper makes about “call[ing] into question the ability of Member States to honor their bilateral tax treaties” might be true, but the specifics of …
The Psychological Autopsy In Judicial Opinions Under Section 2035, Thomas L. Shaffer
The Psychological Autopsy In Judicial Opinions Under Section 2035, Thomas L. Shaffer
Thomas L. Shaffer
No abstract provided.