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Full-Text Articles in Law
Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault
Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault
Hugh J. Ault
No abstract provided.
Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault
Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Oecd Conference On Intangibles, Hugh Ault
Panelist, Oecd Conference On Intangibles, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault
Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault
Hugh J. Ault
No abstract provided.
Transfer Pricing, Hugh Ault
Transfer Pricing, Hugh Ault
Hugh J. Ault
Chaired meeting of 45 governmental and academic specialist
Panelist, The International Network For Tax Research And The American Journal Of Comparative, Conference On "Comparative Tax Law: Theory And Practice, Hugh Ault
Hugh J. Ault
No abstract provided.
Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault
Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault
Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault
Hugh J. Ault
No abstract provided.
2008 Oecd Model: The New Arbitration Provision, Hugh Ault
2008 Oecd Model: The New Arbitration Provision, Hugh Ault
Hugh J. Ault
New Art. 25(5), added to Art. 25 (Mutual agreement procedure) of the OECD Model as part of the 2008 Update, provides for the mandatory arbitration of unresolved issues arising in the course of a mutual agreement procedure. This article first examines the various factors that led to the adoption of Art. 25(5) and the stages of its development by the OECD. The article then discusses some technical aspects of the new arbitration provision, including the Sample Mutual Agreement setting out some procedural rules, which is attached as an Annex to Art. 25.
Session Chair, Oecd Advisory Group For Co-Operation With Non-Oecd Countries, Hugh Ault
Session Chair, Oecd Advisory Group For Co-Operation With Non-Oecd Countries, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault
Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault
Hugh J. Ault
No abstract provided.
Reflections On The Role Of The Oecd In Developing International Tax Norms, Hugh Ault
Reflections On The Role Of The Oecd In Developing International Tax Norms, Hugh Ault
Hugh J. Ault
On September 8–9, 2008, the Organisation for Economic Cooperation and Development (“OECD”) held a Special Conference commemorating the 50th Anniversary of the OECD Model Tax Convention (“Model Convention” or “Model”). The Conference was attended by over 650 participants from the private sector and the government, representing over 100 countries. Both the level of participation and the geographical diversity represented at the conference would seem concrete evidence of the perceived importance of the role of the OECD in developing international tax norms. In his remarks opening the conference, the OECD Secretary General noted that the success of the OECD Model was …
Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda
Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda
Hugh J. Ault
In a practice article, Mitsuhiro Honda and Hugh J. Ault comment on a Tokyo High Court ruling that held that Japan's controlled foreign corporation rules are consistent with article 7(1) of the Japan-Singapore tax treaty.
Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault
Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault
Hugh J. Ault
No abstract provided.
Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault
Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault
Hugh J. Ault
No abstract provided.
Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault
Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault
Hugh J. Ault
No abstract provided.
Improving The Resolution Of International Tax Disputes, Hugh Ault
Improving The Resolution Of International Tax Disputes, Hugh Ault
Hugh J. Ault
The dramatic increase in international trade and investments and related phenomena under the general heading of Globalization have multiplied the situations in which international tax disputes can arise, both between taxpayers and governments but also, and in some ways, more importantly, between governments themselves. These disputes may involve transfer pricing issues, differing income characterization rules, disagreement about the existence of a permanent establishment, or more generally, diverging views on the appropriate exercise of potential taxing rights by the source country jurisdiction and the corresponding obligation of the residence country to provide double tax relief. In the current circumstances, it seems …
Review Of Foundations Of International Income Taxation, By Michael Graetz, Hugh Ault
Review Of Foundations Of International Income Taxation, By Michael Graetz, Hugh Ault
Hugh J. Ault
No abstract provided.
U.S. Exemption/Territorial System Vs. Credit-Based System, Hugh Ault
U.S. Exemption/Territorial System Vs. Credit-Based System, Hugh Ault
Hugh J. Ault
No abstract provided.
Taxation Of Income From Mobil Capital: Some Recent International Developments, Hugh Ault
Taxation Of Income From Mobil Capital: Some Recent International Developments, Hugh Ault
Hugh J. Ault
No abstract provided.
U.S. Corporate Taxation Reform From An International Perspective, Hugh Ault
U.S. Corporate Taxation Reform From An International Perspective, Hugh Ault
Hugh J. Ault
No abstract provided.
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Hugh J. Ault
No abstract provided.
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Hugh J. Ault
No abstract provided.
Federal Income Taxation Of Business Organizations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation Of Business Organizations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1998 Supplement: Federal Income Taxation of Business Organizations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; Special 1997 Legislative Supplement: Federal Income Taxation of Business Organizations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1998 Supplement: Federal Income Taxation of Partnerships and S Corporations. 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; 1997 Supplement to Federal Income Taxation of Partnerships and S Corporations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1995 Supplement to Federal Income Taxation, Cases and Materials. 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1995; 1997 Supplement to Federal Income Taxation: Cases and Materials, 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
Hugh J. Ault
An updated version appears inIntertax 4 (April 1994): 144-148.
The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault
The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault
Hugh J. Ault
No abstract provided.
Federal Income Tax Project: International Aspects Of United States Income Taxation Ii: Proposals Of The American Law Institute On United States Income Tax Treaties, Hugh Ault, David Tillinghast
Federal Income Tax Project: International Aspects Of United States Income Taxation Ii: Proposals Of The American Law Institute On United States Income Tax Treaties, Hugh Ault, David Tillinghast
Hugh J. Ault
No abstract provided.