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Full-Text Articles in Law
Fishing For Rainbows, The Fsc Repeal And Extraterritorial Income Exclusion Act, Stuart Smith
Fishing For Rainbows, The Fsc Repeal And Extraterritorial Income Exclusion Act, Stuart Smith
San Diego International Law Journal
On August 30, 2002, the final decision was released in the case of United States-Tax Treatment for "Foreign Sales Corporations". The World Trade Organization arbitration panel report authorizes the European Communities to levy $4.043 billion in annual trade sanctions against imports from the United States because of a provision in the U.S. tax code. "The FSC Repeal and Extraterritorial Income Exclusion Act of 2000", the most recent of 40 years worth of half-hearted attempts by the United States to comply with world trading body regulations, is the current offender. According to the arbitration panel, the act subsidizes foreign sales by …
Exchanges Of Multiple Stocks And Securities In Corporate Divisions Or Acquisitive Reorganizations, Douglas A. Kahn, Jeffrey S. Lehman
Exchanges Of Multiple Stocks And Securities In Corporate Divisions Or Acquisitive Reorganizations, Douglas A. Kahn, Jeffrey S. Lehman
Articles
If specified conditions are satisfied, the Internal Revenue Code provides nonrecognition for gain or loss realized when stocks and securities of one corporation are exchanged for stocks and securities of another corporation. When the exchange is made as part of a corporate division (a split-off or a split-up), the principal nonrecognition provision is section 355; and when the exchange is made as part of an acquisitive reorganization, the principal nonrecognition provision is section 354. Complete nonrecognition is provided only when stock is exchanged solely for stock and securities are exchanged solely for securities of no greater principal amount. If, in …
Tax Competition: Harmful To Whom?, Michael Littlewood
Tax Competition: Harmful To Whom?, Michael Littlewood
Michigan Journal of International Law
The aim of this paper is to examine the theory that it is both desirable and feasible to prevent less-developed countries from operating preferential tax regimes (that is, offering tax incentives) as a means of attracting foreign investment.