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- Corporations -- Taxation (4)
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Articles 1 - 27 of 27
Full-Text Articles in Taxation-Transnational
Moore V. United States: The U.S. Supreme Court’S Impending Revisiting Of The Definition Of “Income”, Beckett Cantley, Geoffrey Dietrich
Moore V. United States: The U.S. Supreme Court’S Impending Revisiting Of The Definition Of “Income”, Beckett Cantley, Geoffrey Dietrich
University of Miami Business Law Review
The passing of the Tax Cuts and Jobs Act (“TCJA”) in December 2017 made significant changes that affect both domestic and international businesses income taxes. One of the most notable changes involves the Internal Revenue Code (“IRC”) section 965 transition tax on foreign earnings of foreign subsidiaries of U.S. companies, which deems those earnings to be repatriated. Effectively, this transition tax disregards the realization element thought by some to be a U.S. Constitutional requirement. As such, questions have arisen in the courts regarding the constitutionality of these laws. The most noteworthy case of Moore v. United States has found its …
Jotwell's Thirteenth Birthday Celebration, A. Michael Froomkin
Jotwell's Thirteenth Birthday Celebration, A. Michael Froomkin
Articles
No abstract provided.
How Hard Can This Be? The Dearth Of U.S. Tax Treaties With Latin America, Patricia A. Brown
How Hard Can This Be? The Dearth Of U.S. Tax Treaties With Latin America, Patricia A. Brown
University of Miami Law Review
The United States has fewer tax treaties with countries in Latin America and the Caribbean than the United Kingdom, France, Germany, Spain and even China have with such countries. After first describing ways in which tax treaties reduce barriers to cross-border trade and investment, this Article considers in turn various possible explanations for this situation. It examines, and rejects, the hypothesis that Latin American countries are reluctant to enter into tax treaties in general. It then considers, and rejects, the possibility that Latin American countries are opposed to in-creased trade and investment from the United States in particular. It then …
United States Policy And The Taxation Of International Intangible Income, Stanley I. Langbein
United States Policy And The Taxation Of International Intangible Income, Stanley I. Langbein
University of Miami Inter-American Law Review
No abstract provided.
Follow The Money: A Discussion Of The Organisation For Economic Co-Operation And Development’S Base Erosion And Profit Shifting Project: Has The Us Taken Steps To Adopt A Global Solution To This Worldwide Problem?, Claire Arritola
University of Miami Business Law Review
This article looks at the recent actions taken by the Organisation for Economic Co-operation and Development (OECD) to prevent hybrid mismatches and tax base erosion. These actions have come in the form of the “Action Plan for Base Erosion and Profits” (BEPS). BEPS has spanned from 2013 to 2015 and has been the collaborative effort of representatives from 34 countries (with much help from the G-20 countries) as well as input from other non-member countries. Through this project, the OECD seeks to eradicate the problems caused by the current corporate tax structure and the tendency of countries to choose country-specific …
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
Articles
No abstract provided.
A Review Of International Business Tax Reform, Alexander M. Lewis
A Review Of International Business Tax Reform, Alexander M. Lewis
University of Miami International and Comparative Law Review
No abstract provided.
Doing The Math (And The English) In The Windfall Tax Cases, Stanley I. Langbein
Doing The Math (And The English) In The Windfall Tax Cases, Stanley I. Langbein
Articles
No abstract provided.
Ppl, The Foreign Tax Credit, And The Gitlitz “Finger” Principle, Stanley I. Langbein
Ppl, The Foreign Tax Credit, And The Gitlitz “Finger” Principle, Stanley I. Langbein
Articles
No abstract provided.
Cognitive Capture, Parliamentary Parentheses, And The Rise Of Fractional Apportionment, Stanley I. Langbein
Cognitive Capture, Parliamentary Parentheses, And The Rise Of Fractional Apportionment, Stanley I. Langbein
Articles
No abstract provided.
Expatriation, Double Taxation, And Treaty Override: Who Is Eating Crow Now?, Christine L. Agnew
Expatriation, Double Taxation, And Treaty Override: Who Is Eating Crow Now?, Christine L. Agnew
University of Miami Inter-American Law Review
No abstract provided.
An Overview Of International Tax Issues, Joseph H. Guttentag
An Overview Of International Tax Issues, Joseph H. Guttentag
University of Miami Law Review
No abstract provided.
Tax Treaty Issues, David R. Tillinghast
Tax Treaty Issues, David R. Tillinghast
University of Miami Law Review
No abstract provided.
Structuring Foreign Investment In United States Real Estate, William H. Newton Iii
Structuring Foreign Investment In United States Real Estate, William H. Newton Iii
University of Miami Law Review
No abstract provided.
Foreign Tax Problems Of U.S. Companies Doing Business In Latin America, Peter D. Byrne
Foreign Tax Problems Of U.S. Companies Doing Business In Latin America, Peter D. Byrne
University of Miami Law Review
No abstract provided.
Source-Basis Taxation Of Derivative Financial Instruments: Some Unanswered Questions, H. David Rosenbloom
Source-Basis Taxation Of Derivative Financial Instruments: Some Unanswered Questions, H. David Rosenbloom
University of Miami Law Review
No abstract provided.
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
University of Miami Law Review
No abstract provided.
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
University of Miami Law Review
No abstract provided.
International Criminal Tax Cases, Cono R. Namorato, Scott D. Michel
International Criminal Tax Cases, Cono R. Namorato, Scott D. Michel
University of Miami Law Review
No abstract provided.
U.S. Final Transfer Pricing Regulations, John S. Nolan
U.S. Final Transfer Pricing Regulations, John S. Nolan
University of Miami Law Review
No abstract provided.
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
University of Miami Inter-American Law Review
No abstract provided.
The Continuing Viability Of The Banking And Financial Disc: A Tool For Sheltering Export Finance Income, Ricardo Corona
The Continuing Viability Of The Banking And Financial Disc: A Tool For Sheltering Export Finance Income, Ricardo Corona
University of Miami Inter-American Law Review
No abstract provided.
Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White
Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White
Articles
No abstract provided.
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
An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White
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 …
Hawaii Tax Held Invalid: Court Decides First Case Of The Term, Patricia D. White
Hawaii Tax Held Invalid: Court Decides First Case Of The Term, Patricia D. White
Articles
Aloha Airlines, Inc.
v.
Director of Taxation, State of Hawaii (Docket No. 82-585)
Hawaiian Airlines, Inc.
v.
Director of Taxation, State of Hawaii (Docket No. 82-566)
Argued October 4. 1983. Decided November 1, 1983
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
Articles
No abstract provided.