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Articles 1 - 10 of 10
Full-Text Articles in Law
A Proposal For The Tax Treatment Of Interest In A Territorial System, Martin A. Sullivan
A Proposal For The Tax Treatment Of Interest In A Territorial System, Martin A. Sullivan
Pepperdine Law Review
To prevent negative effective tax rates in a territorial system, a multinational corporation’s deductions for interest expense attributable to foreign profits must be disallowed. To determine what portion of worldwide interest is foreign, it is commonly suggested that interest be allocated in proportion to assets. Because it would ease administrative problems and because it would reduce the incentives to shift profits through aggressive transfer pricing, allocation of interest in proportion to gross profits would be a superior approach. Also, contrary to the usual argument, the United States should not be reluctant to unilaterally adopt interest disallowance rules because it would …
Corporate And International Tax Reform: Proposals For The Second Obama Administration (And Beyond), Reuven S. Avi-Yonah
Corporate And International Tax Reform: Proposals For The Second Obama Administration (And Beyond), Reuven S. Avi-Yonah
Pepperdine Law Review
The passage of the American Taxpayer Relief Act of 2012 (“ATRA”) offers an opportune moment to consider proposals for corporate and international tax reform. With the debate over individual tax rates for the income and estate tax settled for the present, the President and Congress are free to consider broader reforms. This paper will attempt to raise some proposals for US corporate and international tax reform, beginning with long-term options (a 10 year horizon), continuing with the medium term (2-5 years) and concluding with short-term options (1-2 years). The main proposals are for the US to adopt a VAT and …
The Globalization Of Corporate Tax Reform, Steven A. Bank
The Globalization Of Corporate Tax Reform, Steven A. Bank
Pepperdine Law Review
With the growth of multinational corporations and its effect on corporate tax revenues, it is not surprising that international tax reform is a major part of President Obama’s Framework for Business Tax Reform as he begins his second term. Noticeably missing from this and other discussions of the major structural reform proposals, however, is any mention of the influence and importance of international corporate tax reform efforts. Although the concern over corporate tax evasion is especially pronounced in the U.S., the "decentering" of multinational corporations and corporate tax revenues is by no means an exclusively American problem. Around the world, …
Toward An International Standard Of Environment, George P. Smith Ii
Toward An International Standard Of Environment, George P. Smith Ii
Pepperdine Law Review
No abstract provided.
International Law Of Outer Space And Its Effect On Commercial Space Activity, James J. Trimble
International Law Of Outer Space And Its Effect On Commercial Space Activity, James J. Trimble
Pepperdine Law Review
The United Nations, through a series of five treaties, has created a body of international space law which controls the activities in space of states, international organizations, and private interests. Corporations planning an investment in commercial space ventures must consider the restrictions and obligations which space law will impose on their activities. This article discusses the substantive principles of the law of outer space and focuses on those provisions which will affect commercial space activities.
The Law Of The Sea: Offshore Installations And Marine Pollution, John Warren Kindt
The Law Of The Sea: Offshore Installations And Marine Pollution, John Warren Kindt
Pepperdine Law Review
No abstract provided.
Lessons From The Hague - An Update On The Iran-United States Claims Tribunal , Richard M. Mosk
Lessons From The Hague - An Update On The Iran-United States Claims Tribunal , Richard M. Mosk
Pepperdine Law Review
No abstract provided.
The United States Government As Defendant - One Example Of The Need For A Uniform Liability Regime To Govern Outer Space And Space-Related Activities, Joseph A. Bosco
The United States Government As Defendant - One Example Of The Need For A Uniform Liability Regime To Govern Outer Space And Space-Related Activities, Joseph A. Bosco
Pepperdine Law Review
No abstract provided.
Friendship, Commerce, And Navigation Treaties: An Analysis Of The Foreign Corporation's Exemption From United States Labor Standards , Gregory S. Lane
Friendship, Commerce, And Navigation Treaties: An Analysis Of The Foreign Corporation's Exemption From United States Labor Standards , Gregory S. Lane
Pepperdine Law Review
No abstract provided.
Municipal And State Sanctuary Declarations: Innocuous Symbolism Or Improper Dictates?, Jorge L. Carro
Municipal And State Sanctuary Declarations: Innocuous Symbolism Or Improper Dictates?, Jorge L. Carro
Pepperdine Law Review
No abstract provided.