Law Commons^™

Tax Competition And Tax Cooperation: A Survey And Reassessment, Hugh J. Ault

Hugh J. Ault

No abstract provided.

Arbitration And International Institutions, Hugh Ault

Hugh J. Ault

Base Erosion And Profit Shifting: A Roadmap For Reform, Hugh Ault, Wolfgang Schoen, Stephen Shay

Hugh J. Ault

In this Editorial, the authors explain the context of this special issue of the Bulletin for International Taxation. The fundamental premise of the BEPS project is that a coordination of national responses to BEPS can both eliminate double non-taxation and protect against material unrelieved double taxation. The articles in this issue further a dialogue among tax policymakers, taxpayers, advisors and academics that is critical to achieve this objective.

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

Hugh J. Ault

No abstract provided.

Dispute Resolution: The Mutual Agreement Procedure, Hugh Ault

Hugh J. Ault

No abstract provided.

Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault

Hugh J. Ault

This article is the revised text of a lecture held on May 2, 2013, at the Max Planck Institute for Tax Law and Public Finance. It focuses on the OECD's work on the definition of Permanent Establishment, the transfer pricing treatment of Intangibles and the recently announced project on base erosion and profit shifting ("BEPS"). After describing these positive law developments, Ault relates to more basic questions of how principles of international tax law, and particular the normative claims to taxing rights, are established.

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

Hugh J. Ault

No abstract provided.

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

Hugh J. Ault

No abstract provided.

The Recent Oecd Developments And The European Tax Integration Process, Hugh Ault

Hugh J. Ault

No abstract provided.

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

Hugh J. Ault

No abstract provided.

Introduction, Comparative Income Taxation: A Structured Analysis, Hugh J. Ault, Brian J. Arnold

Hugh J. Ault

This work presents a comparative analysis of some of the structural and design issues which are involved in mature income tax systems. Countries selected for the study are Australia, Canada, France, Germany, Japan, The Netherlands, Sweden, the United Kingdom and the United States. Each of the systems has evolved its own particular set of approaches and principles, outlined in Part One. Ensuing Parts deal with Basic Income Taxation, Taxation of Business Organizations and International Taxation. There is much to learn in the tax field from a comparative analysis of common problems. One need not believe in the existence of a …

The Importance Of Comparative Law In Legal Education: United States Goals And Methods Of Legal Comparisons, Hugh J. Ault, Mary Ann Glendon

Hugh J. Ault

This Essay discusses the gradual changes occurring within legal education, which are finding wide acceptance in law schools throughout the United States. These changes include greater attention to other disciplines, primarily economics and behavioral sciences, and the contributions they make to a fuller understanding of the legal system. In addition, law schools are increasingly exploring the ways in which the law in textbooks may differ from the law in action. Nearly every law school, therefore, is seriously investigating the social and economic background of legal rules and their consequences through clinical legal education, which attempts to provide a real or …

Oecd Project On Harmful Tax Practices, Hugh J. Ault

Hugh J. Ault

Materials presented in conjunction with a keynote speech delivered on May 15, 2003 at a congress on Tax Competition, organized by the European Tax College and held at Tilburg University, the Netherlands.

Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault

Hugh J. Ault

In this Article, Professor Ault begins with an examination of the evolution of treaty principles for the allocation of and restrictions on international taxing jurisdiction. He then focuses on how economically based principles dealing with the taxation of international income affect treaty policy and presents the basic structural provisions involving the taxation of foreign income and foreign investors that emerge from domestically enacted or proposed integration systems. The technical aspects of the actual treaty practices that have been implemented with respect to integration systems are then related to the theoretical discussion. Professor Ault concludes with an examination of the implications …

Taxation And Non-Discrimination: A Reconsideration, Hugh J. Ault, Jacques Sasseville

Hugh J. Ault

No abstract provided.

Panelist, Oecd Conference On Intangibles, Hugh Ault

Hugh J. Ault

No abstract provided.

Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault

Hugh J. Ault

No abstract provided.

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

Hugh J. Ault

No abstract provided.

Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold

Hugh J. Ault

The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime …

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

Hugh J. Ault

No abstract provided.

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

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

Hugh J. Ault

No abstract provided.

Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault

Hugh J. Ault

No abstract provided.