Taxation-Transnational | Open Access Articles

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 …

Go to article

Steuervereinfachung Im Internationalen Vergleich, Hugh Ault Dec 1997

Steuervereinfachung Im Internationalen Vergleich, Hugh Ault

Hugh J. Ault

No abstract provided.

Go to article

Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons Dec 1997

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

Go to article

The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner Dec 1997

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 …

Go to article

Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel Dec 1997