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Taxation-Transnational Commons

Open Access. Powered by Scholars. Published by Universities.®

1998

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Institution
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Articles 1 - 6 of 6

Full-Text Articles in Taxation-Transnational

Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey Dec 1998

Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey

William & Mary Annual Tax Conference

No abstract provided.


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 …


Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green Jan 1998

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 Jan 1998

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 Jan 1998

Migration As International Trade: The Economic Gains From The Liberalized Movement Of Labor, Howard F. Chang

All Faculty Scholarship

No abstract provided.


The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii. Jan 1998

The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii.

Articles & Chapters

No abstract provided.