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Articles 1 - 30 of 84
Full-Text Articles in Law
Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes
Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes
William H. Byrnes
No abstract provided.
Introductory Remarks, 21st Coffin Lecture, Sharon Beckman
Introductory Remarks, 21st Coffin Lecture, Sharon Beckman
Sharon Beckman
No abstract provided.
Invited Participant, United Nations Committee Of Experts On International Tax Matters, Hugh Ault
Invited Participant, United Nations Committee Of Experts On International Tax Matters, Hugh Ault
Hugh J. Ault
No abstract provided.
International Tax Developments And Family Businesses, Hugh Ault
International Tax Developments And Family Businesses, Hugh Ault
Hugh J. Ault
No abstract provided.
Do The Benefits To Russia Of Compliance With The Usa’S Fatca Outweigh Its Russian Costs?, William Byrnes
Do The Benefits To Russia Of Compliance With The Usa’S Fatca Outweigh Its Russian Costs?, William Byrnes
William H. Byrnes
No abstract provided.
Are Some U.S. Agreements More Equal Than Others? Dtas, Tiea, Igas And The U.S. Constitution. Exploring The Executive/Senate Treaty Authority, House Of Representative ‘Origination’ Of Tax Authority, And Congressional Regulation Of Commerce With Foreign Nations Authority, William Byrnes
William H. Byrnes
No abstract provided.
Taxing Indirect Transfers: Improving An Instrument For Stemming Tax And Legal Base Erosion, Wei Cui
Taxing Indirect Transfers: Improving An Instrument For Stemming Tax And Legal Base Erosion, Wei Cui
Wei Cui
Numerous countries (e.g. Canada, Australia and Japan) tax foreigners on the gains realized on transfers of interests in foreign entities that invest directly or indirectly in real estates in these countries. In the last few years, actions taken by tax authorities in India, China, Brazil, Indonesia and other non-OECD countries have highlighted the possibility of taxing a broader range of “indirect share transfers” by foreigners. This Article argues taxing indirect transfers can have vital policy significance in countries where foreign inbound investments are actively traded in offshore markets: it not only deters tax avoidance, but may also stanch “legal base …
Panelist, United Nations International Tax Compact, Technical Meeting On Administration And Negotiation Of Tax Treaties, Hugh Ault
Hugh J. Ault
No abstract provided.
Chair, United Nations, Special Meeting Of Ecosoc On International Cooperation In Tax Matters, Hugh Ault
Chair, United Nations, Special Meeting Of Ecosoc On International Cooperation In Tax Matters, Hugh Ault
Hugh J. Ault
No abstract provided.
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Hugh J. Ault
No abstract provided.
The Oecd And Its Beps Project: Where Are We And Where Are We Going?, Hugh Ault
The Oecd And Its Beps Project: Where Are We And Where Are We Going?, Hugh Ault
Hugh J. Ault
No abstract provided.
The Recent Oecd Developments And The European Tax Integration Process, Hugh Ault
The Recent Oecd Developments And The European Tax Integration Process, Hugh Ault
Hugh J. Ault
No abstract provided.
The Inefficiencies Of Legislative Centralization: Evidence From Chinese Provincial Tax Rate Setting, Wei Cui
The Inefficiencies Of Legislative Centralization: Evidence From Chinese Provincial Tax Rate Setting, Wei Cui
Wei Cui
Legislative power in China is centralized to an unusual degree, both in comparison to other countries and relative to the country’s high degree of administrative decentralization. Given its a priori inefficiencies, this arrangement should be significant from both positive and normative perspectives, but, surprisingly, has received little attention in legal and social scientific scholarship. We devise a novel method for analyzing the inefficiencies of centralization through studying provincial government behavior, examining provincial rate setting for the vehicle and vessel tax (VVT) in 2007 and 2011. Because all provinces have assigned VVT revenue and VVT administration to sub-provincial governments, provincial rate-setting …
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.
Treaty Override Of The Japan-United States Tax Treaty: A Three-Part Analysis Addressing Public Finance & Public Policy, International Relations, And Tax Policy, William Byrnes
William H. Byrnes
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
Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault
Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
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 …
Flying Passports Of Convenience, Karl T. Muth
Flying Passports Of Convenience, Karl T. Muth
Karl T Muth
This paper proposes an economic alternative to the legal construct of citizenship that currently dominates international law.
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.