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Articles 1 - 10 of 10
Full-Text Articles in Taxation-Transnational
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey
William & Mary Annual Tax Conference
No abstract provided.
The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii.
The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii.
Articles & Chapters
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 …
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Cornell Law Faculty Publications
Should Advance Pricing Agreements Be Published?, Kristin E. Hickman
Should Advance Pricing Agreements Be Published?, Kristin E. Hickman
Northwestern Journal of International Law & Business
The purpose of this comment is to review the role and function of the advance pricing agreement process, to examine the merits of both sides' arguments in the BNA suit, and to discuss the policy implications should BNA prevail. While advance pricing agreements are not the ultimate solution to transfer pricing disputes and tax jurisdiction issues, they are a dispute resolution tool worth maintaining, at least until Congress or Treasury provides greater guidance in this area. Sufficient legal basis exists for the courts to find against BNA and rule that advance pricing agreements are exempt from publication under IRC § …
Migration As International Trade: The Economic Gains From The Liberalized Movement Of Labor, Howard F. Chang
Migration As International Trade: The Economic Gains From The Liberalized Movement Of Labor, Howard F. Chang
All Faculty Scholarship
No abstract provided.
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.