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Front Matter (Letter From The Editor, Masthead, Etc.), 2022 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


Application Of Branch Rule In Foreign Base Company Sales Income, Tiago Iorio 2022 San Jose State University

Application Of Branch Rule In Foreign Base Company Sales Income, Tiago Iorio

The Contemporary Tax Journal

No abstract provided.


New Foreign Tax Credit Regulations, Dale Loepp CPA 2022 San Jose State University

New Foreign Tax Credit Regulations, Dale Loepp Cpa

The Contemporary Tax Journal

No abstract provided.


Tax Harmony: The Promise And Pitfalls Of The Global Minimum Tax, Reuven Avi-Yonah, Young Ran (Christine) Kim 2022 University of Michigan Law School

Tax Harmony: The Promise And Pitfalls Of The Global Minimum Tax, Reuven Avi-Yonah, Young Ran (Christine) Kim

Michigan Journal of International Law

The rise of globalization has become a double-edged sword for countries seeking to implement a beneficial tax policy. On one hand, there are increased opportunities for attracting foreign capital and the benefits that increased jobs and tax revenue brings to a society. However, there is also much more tax competition among countries to attract foreign capital and investment. As tax competition has grown, effective corporate tax rates have continued to be cut, creating a “race-to-the-bottom” issue.

In 2021, 137 countries forming the OECD/G20 Inclusive Framework on BEPS passed a major milestone in reforming international tax by successfully introducing the ...


Strategic Incentives For Pillar Two Adoption, Wei Cui 2022 Allard School of Law at the University of British Columbia

Strategic Incentives For Pillar Two Adoption, Wei Cui

All Faculty Publications

I analyze countries’ strategic incentives for adopting elements of the OECD’s Pillar Two proposal for reforming international taxation. I treat the three components of Pillar Two—the Income Inclusion Rule (IIR), the Under-Taxed Profits Rule (UTPR), and the Qualified Domestic Minimum Top-Up Tax (QDMT)—as independent of one another. Countries are assumed to make strategic decisions about whether to adopt each component simultaneously with other countries facing similar choices, each aiming to maximize its own objectives.

I argue that although Pillar Two’s designers aimed to maximize strategic interactions among participating countries, overall, remarkably few incentives for adoption emerge ...


Upaya Pemerintah Terhadap Perlindungan Ekspresi Budaya Tradisional Batik Motif Parang Sebagai Warisan Budaya Dunia, Raden Zulfikar Supinarko Putra 2022 Universitas Indonesia

Upaya Pemerintah Terhadap Perlindungan Ekspresi Budaya Tradisional Batik Motif Parang Sebagai Warisan Budaya Dunia, Raden Zulfikar Supinarko Putra

"Dharmasisya” Jurnal Program Magister Hukum FHUI

Abstract

Batik is not just a design on a piece of cloth, more than that, batik is a soul that blends in the procession of Indonesian society. Since the baby has been carried with a batik cloth, weddings wear batik cloth until when they die they will be covered with batik cloth too usually. This fact become a consideration for UNESCO to establish Indonesian Batik as a Masterpieces of the Oral and Intangible Heritage of Humanity in the Fourth Session of The Intergovernmental Committee. This research uses a normative legal research method that is descriptive and analytical using a statutory ...


Perbedaan Akad Wakalah Bil Ujrah Dan Akad Qard Terhadap Permasalahan Akad Pembelian Barang Dalam Kehidupan Sehari-Hari, Zendy Sellyfio Ardiana 2022 Universitas Indonesia

Perbedaan Akad Wakalah Bil Ujrah Dan Akad Qard Terhadap Permasalahan Akad Pembelian Barang Dalam Kehidupan Sehari-Hari, Zendy Sellyfio Ardiana

"Dharmasisya” Jurnal Program Magister Hukum FHUI

Abstract

The wakalah bil ujrah and qard contract are contracts that often cause difficulties in implementing the purchase of goods in everyday life, both in safekeeping for purchasing goods and for buying and selling in general. Where if it is wrong in its application, it can cause income in a sale and purchase to be haraam due to an error in understanding the contract used and not describing benefit as the core of maqashid al-sharia which has an important role in determining Islamic law. The purpose of this paper is to find out how the solution to the application of ...


Tinjauan Yuridis Dalam Penyelesaian Pelanggaran Ham Berat Melalui Komisi Kebenaran Dan Rekonsiliasi Di Afrika Selatan Dan Indonesia, Tshana Erfandi 2022 Universitas Indonesia

Tinjauan Yuridis Dalam Penyelesaian Pelanggaran Ham Berat Melalui Komisi Kebenaran Dan Rekonsiliasi Di Afrika Selatan Dan Indonesia, Tshana Erfandi

"Dharmasisya” Jurnal Program Magister Hukum FHUI

Abstract

Several countries are currently developing a solution to the problem by establishing a particular commission. The commission works outside the courts, parliament and executive. In Indonesia, In Indonesia. The People's Consultative Assembly set a stipulation regarding the establishment of the National Center for Truth and Reconciliation: (NCTR) in 2000. This stipulation has the intent and purpose for national unity to identify existing problems, determine the conditions that must be made in order to achieve national reconciliation and establish policy direction as a guide to carry out the consolidation of unity of a nation. Whereas in South Africa, the ...


Reflections From The Brink Of Tax Warfare: Developing Countries, Digital Services Taxes, And An Opportunity For More Just Global Governance With The Oecd’S Two-Pillar Solution, Connor L. Smith 2022 Boston College Law School

Reflections From The Brink Of Tax Warfare: Developing Countries, Digital Services Taxes, And An Opportunity For More Just Global Governance With The Oecd’S Two-Pillar Solution, Connor L. Smith

Boston College Law Review

Starting in 2016, many countries enacted digital services taxes (DSTs), a turnover tax that applies to digital companies regardless of whether they have a physical presence in the taxing jurisdiction. After the Organization for Economic Cooperation and Development’s Inclusive Framework reached final agreement on its two-pillar solution to tax challenges in a global digital economy, these unilateral measures went on pause. This Note reflects on the recent DST phenomenon, reconceptualizing the DST debate as part of a broader discourse on global governance and globalization. Although DSTs first emerged in developed countries in the European Union, this Note analyzes developing ...


International Tax, Javier Canosa, Aseem Chawla, Pamela A. Fuller, Chandni Javeri, Priyanka Mongia, Jorge Lopez, Marco Ottenwälder, Jan Neugebauer, Eugenio Romita, Guillermo Villaseñor 2022 Southern Methodist University

International Tax, Javier Canosa, Aseem Chawla, Pamela A. Fuller, Chandni Javeri, Priyanka Mongia, Jorge Lopez, Marco Ottenwälder, Jan Neugebauer, Eugenio Romita, Guillermo Villaseñor

The Year in Review

No abstract provided.


Cross-Border Real Estate, Timur Bondaryev, Olga Ivanova, Felipe Isa Castillo, Avikshit Moral, Apurva Kanvinde 2022 Southern Methodist University

Cross-Border Real Estate, Timur Bondaryev, Olga Ivanova, Felipe Isa Castillo, Avikshit Moral, Apurva Kanvinde

The Year in Review

No abstract provided.


What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums, John D. Patten 2022 Northern Illinois University

What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums, John D. Patten

Honors Capstones

What is insurance for the purposes of a tax deduction? The Internal Revenue Code does not define insurance. Without this definition, taxpayers using alternative insurance products to manage their risks must look to case law to determine whether their arrangements count as tax deductible insurance or non-deductible self-insurance. This paper dives into the four prongs of insurance: insurance risk, risk shifting, risk distributing, and commonly accepted notions of insurance. This paper looks to cases that have dealt with the deduction of captive insurance premiums to provide better insight into the practical application of this test. After discussing the evolution of ...


Tax Incentives In Three Common Markets, Sarah Khaled Alsultan 2022 Kuwait University School of Law

Tax Incentives In Three Common Markets, Sarah Khaled Alsultan

Georgia Journal of International & Comparative Law

There are three approaches to dealing with tax incentives within common markets: permit them, limit them, or harmonize them. Broadly speaking, the United States (U.S.) follows the first approach, the European Union (EU) adopts the second, and the Gulf Cooperation Council (GCC) pursues the third by harmonizing some tax incentives, particularly those offered to the industrial sector. Unlike the U.S. and EU common markets, where incentives have gained significant scholarly attention, no academic literature exists on the legal framework of tax incentives in GCC common market. This work attempts to compensate for this insufficiency in scholarship and compares ...


Global Partnership Should Be The Way Forward To Combat Money Laundering, Maame Nyakoa Boateng 2022 Penn State Dickinson Law

Global Partnership Should Be The Way Forward To Combat Money Laundering, Maame Nyakoa Boateng

Dickinson Law Review

This Comment compares the major anti-money laundering (“AML”) laws in the United States and Iran. This Comment argues that even though the United States is advanced in its compliance approach, without a partnership with countries that are more vulnerable to money laundering attacks, its AML efforts could prove counter-productive because of the inter-connectedness of our world today. Accordingly, this Comment proposes a global partnership between countries with effective AML legislation and countries with less effective AML legislation to combat this complex crime.


Private And Public Sector Models For Entrepreneur, Small Business Owner, And Investor Immigration Pathways, Shane Dizon 2022 New York Law School

Private And Public Sector Models For Entrepreneur, Small Business Owner, And Investor Immigration Pathways, Shane Dizon

Articles & Chapters

No abstract provided.


International Taxes, Sunita Doobay, Daniel Gottfried, Christie Galinski, Gagan Kumar, Jorge Lopez, Elinore Richardson, Eugenio Romita, Guillermo Villaseñor 2022 Southern Methodist University

International Taxes, Sunita Doobay, Daniel Gottfried, Christie Galinski, Gagan Kumar, Jorge Lopez, Elinore Richardson, Eugenio Romita, Guillermo Villaseñor

The Year in Review

No abstract provided.


Apple V. European Commission: Losing The War On Corporate International Transfer Pricing, Beckett Cantley, Geoffrey Dietrich 2022 Northeastern University; Cantley Dietrich, P.C.

Apple V. European Commission: Losing The War On Corporate International Transfer Pricing, Beckett Cantley, Geoffrey Dietrich

Loyola of Los Angeles International and Comparative Law Review

No abstract provided.


The Pillar 2 Undertaxed Payments Rule Departs From International Consensus And Tax Treaties, Jinyan Li 2022 Osgoode Hall Law School of York University

The Pillar 2 Undertaxed Payments Rule Departs From International Consensus And Tax Treaties, Jinyan Li

Articles & Book Chapters

The OECD released pillar 2 model rules last December to provide a template for domestic legislation to implement the agreement reached on October 8, 2021, by almost 140 inclusive framework members on a two-pillar solution to address global ta challenges. The model rules are limited to the income inclusion rule (IIR) and undertaxed payments rule (UTPR) (collectively known as the global anti-base-erosion (GLOBE) regime) in the October agreement. However, and rather surprisingly, the meaning of the letter “P” in the UTPR was effectively changed from payments to profits in the model rules. There was little, if any, public discussion about ...


Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce, Daniel O'Connor 2022 Depaul University College of Law

Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce, Daniel O'Connor

DePaul Business and Commercial Law Journal

No abstract provided.


Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring, Doug Bujakowski, Joan Schmit 2022 Drake University Law School

Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring, Doug Bujakowski, Joan Schmit

DePaul Business and Commercial Law Journal

No abstract provided.


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