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Full-Text Articles in Law
Should Foreign Pension Funds With U.S. Investments Pay U.S. Tax?, Cynthia Blum
Should Foreign Pension Funds With U.S. Investments Pay U.S. Tax?, Cynthia Blum
William & Mary Business Law Review
U.S. and foreign pension funds are investing heavily outside of their home countries. With the aging of the world’s population, this trend will likely intensify. Most countries, including the U.S., accord a tax exemption to certain qualified pension funds organized within their own country; however, when a foreign pension fund invests in the U.S., the U.S. tax code does not recognize its tax exemption. Responding to the need to attract greater investment in U.S. infrastructure, Congress in 2015 enacted a new provision ameliorating the tax treatment of foreign pension plans investing in U.S. real estate. This Article examines whether the …
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael Kirsch
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael Kirsch
Journal Articles
Modern developments raise significant questions about the future importance (or non-importance) of formal citizenship status. For example, while many have interpreted the European Union project, with its emphasis on the free movement of individuals, as portending the decreasing relevance of nationality, recent developments, such as the “Brexit” vote, suggest that national identity remains an important factor for many individuals. While much of the public debate over citizenship focuses on areas, such as immigration, that are more obviously tied to formal citizenship status, this debate also impacts cross-border tax policy.
Over the past decade, several scholars have addressed the use of …