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Articles 1 - 6 of 6
Full-Text Articles in Law
Taxation Of Spin-Off – U.S. And German Corporate Tax Law, Stefan W. Suchan
Taxation Of Spin-Off – U.S. And German Corporate Tax Law, Stefan W. Suchan
Cornell Law School J.D. Student Research Papers
Corporate law provides for a transaction commonly referred to as “spin-off”. The corporate enterprise is divided in (at least) two corporations. The stock of a controlled subsidiary will be distributed pro rata by a parent corporation to its shareholders which end up owning a brother/sister pair of corporate enterprises.
The Internal Revenue Code (IRC) in § 355 provides special rules for the distribution of stock and securities of a controlled corporation. The transaction is known as a “D reorganization”, if such a distribution follows the transfer by a corporation of all or a part of its assets to another corporation, …
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Cornell Law Faculty Publications
This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Cornell Law Faculty Publications
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Cornell Law Faculty Publications
No abstract provided.
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment, Robert A. Green
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment, Robert A. Green
Cornell Law Faculty Publications
[Abstract needed]
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green
Cornell Law Faculty Publications