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Articles 331 - 343 of 343

Full-Text Articles in Taxation-Transnational

Closing The International Tax Gap, Joseph Guttentag, Reuven S. Avi-Yonah Jan 2005

Closing The International Tax Gap, Joseph Guttentag, Reuven S. Avi-Yonah

Book Chapters

In July of 1999, the Justice Department entered into a plea bargain with one John M. Mathewson of San Antonio, Texas. Mr. Mathewson was accused of money laundering through the Guardian Bank and Trust Co. Ltd., a Cayman Islands bank. Mr. Mathewson was chairman and controlling shareholder of Guardian, and in that capacity had access to information on its depositors. In return for a reduced sentence, Mr. Mathewson turned over the names of the persons who had accounts at Guardian. The result was an eye-opener: The majority of the accounts were beneficially owned by U.S. citizens, and the reason they …

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Determinantes Explícitos E Implícitos De La Deuda Externa Pública Peruana, José Manuel Martin Coronado Dec 2003

Determinantes Explícitos E Implícitos De La Deuda Externa Pública Peruana, José Manuel Martin Coronado

José-Manuel Martin Coronado

This research aims to prove that sound economic policies are nothing more that basic conditions for the foreign public debt problem. In fact, by studying the factors of public debt issues in Peru, Latin America and the emerging economies it’s clear that some implicit economic and non-economic factors have to be considered because of the social complexity and variable characteristics in emerging economies. This causes failures in economic policies assumptions, inefficiencies, distorted causality and nonrational behavior. This paper proposes, first, to perform a deep and comparative analysis of the foreign debt determinants in emerging economies, then, to allocate financial resources, …

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Manual De Derecho Procesal Civil, Edward Ivan Cueva Feb 2003

Manual De Derecho Procesal Civil, Edward Ivan Cueva

Edward Ivan Cueva

No abstract provided.

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Teoría General De La Prueba Judicial, Edward Ivan Cueva Jan 2002

Teoría General De La Prueba Judicial, Edward Ivan Cueva

Edward Ivan Cueva

No abstract provided.

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Debt Instruments' Tax Treatment In Corporate Mergers And Acquisitions, Tae Oon Jang Jan 1998

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 …

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Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White Jun 1990

Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White

Articles

No abstract provided.

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Capital Neutrality And Coordinated Supervision: Lessons For International Securities Regulation From The Law Of International Taxation And Banking, Charles Thelen Plambeck Jan 1988

Capital Neutrality And Coordinated Supervision: Lessons For International Securities Regulation From The Law Of International Taxation And Banking, Charles Thelen Plambeck

Michigan Journal of International Law

Part I of this article provides some background on the legal forces which have influenced globalization and internationalization of the world's securities markets. Part II focuses on the international tax law principle of capital neutrality. Fundamentally, the principle of capital neutrality requires that regulations should not unintentionally direct the movement of capital. Part II analyzes the bases and parameters of the principle of capital neutrality, the experiences of international taxation in applying the principle to a globalizing economy, and the possibilities for applying the principle to international securities regulation. Part III focuses on the international banking law principle of coordinated …

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An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White Dec 1983

An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White

Articles

A good deal has been written over the past forty-odd years about the tax benefit rule. Over this period the federal courts have decided many cases in which its application has been at issue, and the law journals have published a small but steady stream of commentary on the rule and its manifestations. Last term, in Hillsboro National Bank v. Commissioner, the Supreme Court issued an opinion that focused squarely, and at some length, on the tax benefit rule. Despite this attention, relatively little has been done to examine the conceptual foundations of the tax benefit rule and to …

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Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris Jan 1980

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 …

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The Secret Foreign Bank Account And Legitimate Alternatives, Charles W. Adams Jan 1971

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.

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Nociones Generales De Derecho Procesal Civil, Edward Ivan Cueva Jan 1966

Nociones Generales De Derecho Procesal Civil, Edward Ivan Cueva

Edward Ivan Cueva

No abstract provided.

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Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba Apr 1964

Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba

Michigan Law Review

The Commissioner of Internal Revenue issued jeopardy assessments against the taxpayer, Omar, S.A., a Uruguayan corporation. To avoid payment, Omar began to liquidate its American-held assets by transferring receipts out of the country. Pursuant to its statutory right, under section 6321 of the Internal Revenue Code of 1954, to impose a lien upon all property of a delinquent taxpayer, the United States brought suit against Omar and various New York banks in the domestic and foreign branches of which Omar's funds were deposited. The district court granted a preliminary injunction restraining certain of the banks from transferring any property whether …

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Fundamentos Del Derecho Procesal Civil, Edward Ivan Cueva Jan 1958

Fundamentos Del Derecho Procesal Civil, Edward Ivan Cueva

Edward Ivan Cueva

No abstract provided.

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