Law Commons^™

United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein

Articles

No abstract provided.

Introduction: The Value-Added Tax - A Symposium, Edwin T. Hood

Faculty Works

On October 22, 1979, Representative Al Ullman, Chairman of the House Ways and Means Committee, introduced H.R. 5665, the Tax Restructuring Act of 1979. Representative Ullman proclaimed the bill, which contains a ten percent value-added tax, as the "largest adjustment in U.S. taxation since 1913." In his statement accompanying the introduction of H.R. 5665, Chairman Ullman states that the overall purpose for the imposition of a value-added tax coupled with reductions in social security and income taxes, is to correct major flaws in the United States economy-namely double digit inflation, declining productivity, inadequate capital formation, and lag­ging competition with foreign …

Taxation Aspects Of Foreign Investments In India, Udai V. Singh

LLM Theses and Essays

This paper will outline, discuss and suggest changes in various provisions of the Income Tax Act, 1961, applying to foreign investments. Chapter II of this paper explores the general underlying principles of the Indian tax system. Chapter III discusses the tax liability of foreign personnel in India and special tax incentives granted to foreign technicians. Chapter IV discusses the system of corporate taxation or “resident” and non-resident” companies and tax liability of foreign collaborators. Special attention is paid to the liability arising out of various trading activities of non-resident companies in India and many problems of judicial determination relating to …

Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris

Faculty Scholarship

The more one reads about our economy, the more one is baffled and alarmed. Permanent solutions to economic problems are elusive. Treating one financial malaise often aggravates another sector of the economy, necessitating a delicate balancing of conflicting interests. Furthermore, the problems are complicated by the constant influence of foreign forces. Nevertheless, most economists agree that any solution will require enormous funding. Unfortunately, the public has little, if any, confidence in our tax system. Indeed, some tax laws and proposals have been referred to as "obscene" and a "disgrace to the human race." Few quarrel with the aptness of such …

Tax Measures In Response To The Brain Drain, Richard Pomp, Oliver Oldman

Faculty Articles and Papers

Emigration results in the loss of skilled manpower for many countries. The widespread movement of skilled workers (PTKs) from less developed countries (LDCs) to developed countries (DCs) is particularly concerning. This emigration, referred to as the “brain drain”, creates two major concerns for LDCs: (1) slowing economic development, and (2) exploitation by DCs. As a result, LDCs have a growing resentment toward DCs, which leads to irrational discussion and a lack of solutions. The absence of reliable statistics has also greatly impeded progress.

This article discusses proposals for solutions to the brain drain issue. Part I addresses the problem, and …

The Reverse Transfer Of Technology: Legal And Administrative Aspects Of Compensation, Taxation And Related Policy Measures, Richard Pomp, Oliver Oldman

Faculty Articles and Papers

This study discusses the legal and administrative implications of transferring to the developing countries part of the benefits accruing to both the migrants and to the developed countries from the reverse transfer of technology, or brain drain. Brain drain is an expression used to indicate the migration of professional, technical, and kindred persons (PTKs) from the developing countries to the developed. This is causing concern regarding the effect this loss of manpower is having on the economies of the developing countries.

The causes of brain drain are complex, and a number of remedies have been suggested at various times to …

The United States Interest Equalization Tax, Richard Pomp

Faculty Articles and Papers

The United States Interest Equalization tax is a one-time tax levied on certain foreign securities, proposed by President Kennedy in order to reduce the balance-of-payments deficit by restricting portfolio investment. Although the tax was enacted in 1964 as a short-term measure, it was continually extended and amended. This article explores the contours of the tax.

Prior to the tax, many foreign debt issues were attracting large amounts of capital due to their high interest rates. The IET attempts to equalize the yield of foreign debt issues with domestic debt issues by imposing a tax on the foreign issues and thus …

Comparative Analysis Of Depreciation In The Common Market: United Kingdom, Richard Pomp

Faculty Articles and Papers

This article is a part of European Taxation’s continuing study of fiscal depreciation in the European economic community and focuses on the United Kingdom. It incorporates changes made by the Finance Act of 1972.

There are eight categories of capital expenditure for which depreciation, or capital allowances, are allowed and taken into account for income tax purposes. These categories include industrial buildings; plants and machinery; mines, oil wells, and other natural mineral deposits of a wasting nature; dredging; agricultural and forestry buildings; scientific research; patents; and know-how.

While there is considerable variation in the rules that apply to each category, …

The Secret Foreign Bank Account And Legitimate Alternatives, Charles W. Adams

Articles, Chapters in Books and Other Contributions to Scholarly Works

The author, a member of the California State Bar and consultant, Euro-Dutch Trust Company, George Town, Grand Cayman, B. W. I., labels the use of the secret foreign bank account "foolish and lazy." He suggests that the taxpayer can reduce his tax bite through tax deferral planning, an area in which legislation has been continued and expanded.

Tax Collection From Estates Of Nonresidents, Robert Whitman

Faculty Articles and Papers

No abstract provided.

Income Averaging, M. Carr Ferguson, Edwin T. Hood

Faculty Works

No abstract provided.

Section 482 And Its Effects On International Business Transactions, S. M. Frohlich

William & Mary Annual Tax Conference

No abstract provided.

Trends In The Taxation Of Foreign Income, M. Bernard Aidinoff

William & Mary Annual Tax Conference

No abstract provided.

Integration And Economic Development, Robert Birmingham

Faculty Articles and Papers

No abstract provided.