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Articles 421 - 450 of 502
Full-Text Articles in Business Organizations Law
Teoría General De La Prueba Judicial, Edward Ivan Cueva
Teoría General De La Prueba Judicial, Edward Ivan Cueva
Edward Ivan Cueva
No abstract provided.
Foreign Direct Investment In Latin America Overview And Current Status, Reuven S. Avi-Yonah, Martin B. Tittle
Foreign Direct Investment In Latin America Overview And Current Status, Reuven S. Avi-Yonah, Martin B. Tittle
Other Publications
More firms than ever, and in more industries and countries, are expanding abroad through [foreign] direct investment [FDI]. Although FDI in 1980 was equivalent to only 5% of world GDP, by the end of the 1990's, that percentage had more than tripled to 17%. In 1993, the total US dollar value of world FDI was only US$ 200 billion, but by the year 2000, it had risen to US$ 1.3 thousand billion. Developing countries received around 25% of these inflows, mostly in the form of "greenfield" investments, where a new enterprise is essentially created from scratch.
Tax Competition And E-Commerce, Reuven S. Avi-Yonah
Tax Competition And E-Commerce, Reuven S. Avi-Yonah
Articles
In the last four years, there has been increasing concern by developed countries about the potential erosion of the corporate income tax base by "harmful tax competition" (in the European Union since 1997, in the OECD since 1998). However, the data on tax competition available to date present a mixed and somewhat puzzling picture. On the one hand, there is considerable evidence that effective corporate income tax rates in many countries have been declining, and that the worldwide effective tax rates on multinational enterprises (MNEs) have been going down as well. On the other hand, macroeconomic data from developed countries …
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Articles
This article analyses the effects of tax competition on developing countries. Since the 1980s, globalization and greater capital mobility have led many developing countries to adopt the policy of competing with one another to attract capital investment. One of the main forms taken by this competition has been the granting of tax holidays and other tax reductions to investing multinationals. This paper reviews the normative arguments for and against this type of tax competition, from a global perspective. It then examines these arguments in depth from the point of view of developing countries. The conclusion in general is that, since …
Arbitration In International Tax Matters: Some Structural Issues, Hugh Ault
Arbitration In International Tax Matters: Some Structural Issues, Hugh Ault
Hugh J. Ault
No abstract provided.
The Importance Of International Cooperation In Forging Tax Policy, Hugh J. Ault
The Importance Of International Cooperation In Forging Tax Policy, Hugh J. Ault
Hugh J. Ault
No abstract provided.
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Articles
This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Hugh J. Ault
No abstract provided.
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Hugh J. Ault
No abstract provided.
Bonus Questions--Executive Compensation In The Era Of Pay For Performance, Charles M. Yablon
Bonus Questions--Executive Compensation In The Era Of Pay For Performance, Charles M. Yablon
Faculty Articles
No abstract provided.
Tax Simplification From A Comparative Point Of View, Hugh Ault
Tax Simplification From A Comparative Point Of View, Hugh Ault
Hugh J. Ault
No abstract provided.
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Hugh J. Ault
No abstract provided.
Debt Instruments' Tax Treatment In Corporate Mergers And Acquisitions, Tae Oon Jang
Debt Instruments' Tax Treatment In Corporate Mergers And Acquisitions, Tae Oon Jang
LLM Theses and Essays
The increase of merger and acquisition(M&A) activity since 1992 has resulted mainly from a domestic economic recovery. The current M&A trend shows that M&A is still an important means of enhancing many corporations' competitive power and of stimulating growth in such areas as computer software and services, wholesale and distribution, miscellaneous services, banking and finance, and leisure and entertainment. Fundraising for mezzanine-fund financing, which reflects investors' foresight about current and future M&A trends, has also seen rapid growth. After the Tax Reform Act of 1986 and the repeal of the General Utilities doctrine, the elimination of the capital gain preference …
Steuervereinfachung Im Internationalen Vergleich, Hugh Ault
Steuervereinfachung Im Internationalen Vergleich, Hugh Ault
Hugh J. Ault
No abstract provided.
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 2000 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2000; 2003 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2003
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
Hugh J. Ault
In response to pressures created by the increasing globalization of the world economy, the OECD has issued a report titled “Harmful Tax Competition: An Emerging Global Issue” that provides an analysis of the phenomenon known as harmful tax competition. The Report identifies factors that characterize tax havens and harmful preferential tax regimes and recommends numerous measures in the areas of domestic legislation, tax treaties, and international cooperation, that countries may pursue to counter harmful tax competition. As part of intensifying international cooperation, the Report recommends that Member countries adopt a set of Guidelines endorsing the “3 R’s:” to refrain, to …
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Hugh J. Ault
No abstract provided.
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
LLM Theses and Essays
This thesis is going to describe the different ways the United States and Germany deal with the problem of double taxation in the legal context of corporate distributions to its shareholders in the form of dividends. Tax law is particularly one of the areas of laws that are subject to frequent and often substantial changes. This is true for the German as well as for the U.S. tax laws. Since some of the issues being discussed in the United States today in connection with the corporate tax law are similar if not identical to the issues discussed in Germany before …
Beyond Marking: Country Of Origin Rules And The Decision In Cpc International, 31 J. Marshall L. Rev. 179 (1997), Donna L. Bade
Beyond Marking: Country Of Origin Rules And The Decision In Cpc International, 31 J. Marshall L. Rev. 179 (1997), Donna L. Bade
UIC Law Review
No abstract provided.
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1998 Supplement: Federal Income Taxation of Partnerships and S Corporations. 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; 1997 Supplement to Federal Income Taxation of Partnerships and S Corporations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
Comparative Income Taxation : A Structural Analysis, Hugh Ault
Comparative Income Taxation : A Structural Analysis, Hugh Ault
Hugh J. Ault
No abstract provided.
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 Impact Of Tax Rules On Corporate Governance, Hugh Ault
The Impact Of Tax Rules On Corporate Governance, Hugh Ault
Hugh J. Ault
No abstract provided.
China's New Foreign Trade Law: Analysis And Implications For China's Gatt Bid, 28 J. Marshall L. Rev. 495 (1995), Bing Wang
UIC Law Review
No abstract provided.
Intercompany Transfer Pricing Regulations Under Internal Revenue Code Section 482: The Noose Tightens On Multinational Corporations, 28 J. Marshall L. Rev. 915 (1995), Michael Avramovich
Intercompany Transfer Pricing Regulations Under Internal Revenue Code Section 482: The Noose Tightens On Multinational Corporations, 28 J. Marshall L. Rev. 915 (1995), Michael Avramovich
UIC Law Review
No abstract provided.
China's New Vat System, 28 J. Marshall L. Rev. 619 (1995), Xiangyuan Jiang, Jack Huang
China's New Vat System, 28 J. Marshall L. Rev. 619 (1995), Xiangyuan Jiang, Jack Huang
UIC Law Review
No abstract provided.
The Forgotten Link: Control In Section 482, Wayne M. Gazur
The Forgotten Link: Control In Section 482, Wayne M. Gazur
Publications
The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1995 Supplement to Federal Income Taxation, Cases and Materials. 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1995; 1997 Supplement to Federal Income Taxation: Cases and Materials, 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
Hugh J. Ault
An updated version appears inIntertax 4 (April 1994): 144-148.