Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Capital expenditures (1)
- Commissioner v. Tufts (1)
- Corporate income taxation (1)
- EC (1)
- European Community treaty (1)
-
- G.M. Leasing Corp. v. United States (1)
- GATT (1)
- General Agreement on Tariffs and Trade (1)
- International taxation (1)
- Justice Harry Blackmun (1)
- NAFTA (1)
- Non-tax treaties (1)
- North American Free Trade Agreement (1)
- Residence-based taxation (1)
- Source-based income taxation (1)
- Tax jurisprudence (1)
- Tax teaties (1)
- Transfer price manipulation (1)
- United States v. Carlton (1)
- WTO (1)
- World Trade Organization agreement (1)
- File Type
Articles 1 - 3 of 3
Full-Text Articles in Taxation-Federal
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert Green
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert Green
Robert A. Green
No abstract provided.
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Robert A. Green
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.
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Robert A. Green
During his tenure on the Supreme Court, Justice Blackmun was widely regarded as the Court's authority on tax matters. Justice Blackmun viewed tax law not merely as a technical specialty, but as a microcosm of the legal system. His numerous tax opinions involve a wide range of issues of constitutional law, criminal law, administrative procedure, court procedure, and statutory interpretation. This Article begins by discussing two of Justice Blackmun's tax opinions involving constitutional issues. Justice Blackmun refused to create special constitutional rules for tax cases. Instead, he applied generally applicable principles, but with great sensitivity to how those principles would …