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Articles 1 - 6 of 6
Full-Text Articles in Taxation-Transnational
Tax Shelters: The New Compliance Environment, D. French Slaughter Iii
Tax Shelters: The New Compliance Environment, D. French Slaughter Iii
William & Mary Annual Tax Conference
No abstract provided.
Tax Aspects Of Doing Business With The People’S Republic Of China, Richard Pomp, Timothy A. Gelatt
Tax Aspects Of Doing Business With The People’S Republic Of China, Richard Pomp, Timothy A. Gelatt
Faculty Articles and Papers
Before 1979, the People’s Republic of China did not have a logical system of taxing foreign business. That summer, a few selected American tax professors met with Chinese tax officials to explain the complexities of source rules, foreign tax credits, and tax treaties. That gave Chinese officials a detailed knowledge of intricate tax issues, and they have used this knowledge to develop China’s new tax system. Since 1979, China’s tax structure has conformed to generally accepted international structures with the adoption of three important taxes affecting foreign business activity. At first, China’s statutes and regulations did not clearly explain the …
A New Export Policy: The Foreign Sales Corporation And State Unitary Taxation Of Foreign Source Income, Reed D. Rubinstein
A New Export Policy: The Foreign Sales Corporation And State Unitary Taxation Of Foreign Source Income, Reed D. Rubinstein
Michigan Journal of International Law
Part I of this note will examine the structure of the FSC, and analyze its potential benefits in light of the Domestic International Sales Corporation (DISC) tax incentive. Part II discusses the use of the unitary tax as a disincentive to direct foreign investment by U.S. corporations. Finally, Part III outlines the new export policy based upon a combination of the FSC export incentive and state unitary taxation of foreign-source income. If implemented, this policy would increase export production and discourage direct foreign investment, thereby making a substantial contribution to U.S. economic well-being.
States' Use Of The Unitary Method: A Taxing Burden On International Commerce, Bryan C. Skarlatos
States' Use Of The Unitary Method: A Taxing Burden On International Commerce, Bryan C. Skarlatos
Penn State International Law Review
This comment will discuss the constitutionality of state use of the unitary method to tax multinational corporations. After considering the problems involved in allocating income between the jurisdictions in which a multinational corporation operates, the comment will examine the two predominant methods of allocation designed to solve these problems. The discussion will then analyze and criticize the Court's decision in Container Corp. v. Franchise Tax Board.
Tax Accrual Workpapers: Protected By A Limited Privilege?, Patricia D. White
Tax Accrual Workpapers: Protected By A Limited Privilege?, Patricia D. White
Articles
United States of America
v.
Arthur Young & Company and Amerada Hess Corporation
(Docket No. 82-687)
To be argued January 16, 1984
Container Corporation Of America V. Franchise Tax Board: State Taxation Of Foreign Income And The Worldwide Combined Unitary Method: The United States Supreme Court Passes The Buck To Congress, 17 J. Marshall L. Rev. 587 (1984), Daniel Frommeyer
UIC Law Review
No abstract provided.