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403 full-text articles. Page 1 of 11.

Tax Inertia: A General Framework With Specific Application To Business Tax Reform, Chris William Sanchirico 2015 University of Pennsylvania Law School & Wharton School

Tax Inertia: A General Framework With Specific Application To Business Tax Reform, Chris William Sanchirico

Faculty Scholarship

A surprising degree of bipartisan consensus has lately formed in the United States around two propositions of business tax reform: that something should be done about the “lockout” of US multinationals’ foreign earnings; and that the corporate income tax rate should be reduced. This paper questions whether these two propositions are really consistent. In the process of attempting to provide an answer, it develops a framework for relating and measuring various forms of “tax inertia”: tax-based disincentives to alter investments. Applying this framework, the paper concludes that the current agreement on business tax reform is substantially in disagreement with itself.


The Crossroads Versus The Seesaw: Getting A 'Fix' On Recent International Tax Policy Developments, Daniel Shaviro 2015 NYU School of Law

The Crossroads Versus The Seesaw: Getting A 'Fix' On Recent International Tax Policy Developments, Daniel Shaviro

New York University Public Law and Legal Theory Working Papers

U.S. international tax policy is at a crossroads, say those who urge the United States to adopt what common parlance would call a territorial system. They argue that one of the two ways forward they identify – trying to fortify the current U.S. system – would lead to ever-costlier outlier status for our tax system, and ever-declining competitiveness for U.S. multinationals. They therefore urge U.S. policymakers to embrace what they identify as the other way forward: conforming to global norms by adopting a territorial system.

An alternative metaphor to that of the crossroads, more likely to appeal to ...


Host Country Taxation Of Transfer Of Technology Transactions, Guillermo Cabanellas, Luis Bertone 2015 University of Buenos Aries

Host Country Taxation Of Transfer Of Technology Transactions, Guillermo Cabanellas, Luis Bertone

Georgia Journal of International & Comparative Law

No abstract provided.


Proposed Congressional Limitations On State Taxation Of Multinational Corporations, Kristen Gustafson 2015 University of Georgia School of Law

Proposed Congressional Limitations On State Taxation Of Multinational Corporations, Kristen Gustafson

Georgia Journal of International & Comparative Law

No abstract provided.


Taxation Aspects Of Foreign Investments In India, Udai V. Singh 2015 University of Georgia School of Law

Taxation Aspects Of Foreign Investments In India, Udai V. Singh

Georgia Journal of International & Comparative Law

No abstract provided.


Sovereign Immunity - Taxation - Residence Of Foreign Sovereign Diplomatic And Consular Staff Is Immune From Taxation Under A Bilateral Agreement And The Foreign Sovereign Immunities Act, Maija S. Blaubergs 2015 University of Georgia School of Law

Sovereign Immunity - Taxation - Residence Of Foreign Sovereign Diplomatic And Consular Staff Is Immune From Taxation Under A Bilateral Agreement And The Foreign Sovereign Immunities Act, Maija S. Blaubergs

Georgia Journal of International & Comparative Law

No abstract provided.


Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram 2015 University of Georgia School of Law

Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram

Georgia Journal of International & Comparative Law

No abstract provided.


Discriminatory Internal Taxation In The European Union: The Power Of The European Court Of Justice To Limit The Tax Sovereignty Of Member-States Under Article 110 Of The Tfeu, Jarrod Tudor 2015 Kent State University - Kent Campus

Discriminatory Internal Taxation In The European Union: The Power Of The European Court Of Justice To Limit The Tax Sovereignty Of Member-States Under Article 110 Of The Tfeu, Jarrod Tudor

Jarrod Tudor

Protectionism can come in a variety of methods including the use of internal taxation policies that discriminate against imports making those imports more expensive on the domestic market and thus favoring domestically-produced goods. Discriminatory taxation policies have been developed by member-states to mask protectionism by distinguishing products based on import status, product similarity, product life cycle, consumption, tax collection practices, transportation charges, and state aid. The Framers of the Treaty on the Functioning of the European Union (TFEU) wrote Article 110 with the objective in mind to prohibit internal taxation policies from discriminating against goods in made in other member-states ...


Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull 2015 University of Georgia School of Law

Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull

Georgia Journal of International & Comparative Law

No abstract provided.


United States Bilateral Investment Treaties: Egypt And Panama, Deidre A. Cody 2015 University of Georgia School of Law

United States Bilateral Investment Treaties: Egypt And Panama, Deidre A. Cody

Georgia Journal of International & Comparative Law

No abstract provided.


Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr. 2015 Notre Dame Law School

Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.

Georgia Journal of International & Comparative Law

No abstract provided.


The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva 2015 Florida International University

The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva

Georgia Journal of International & Comparative Law

No abstract provided.


Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology, Gerald J. Pels 2015 Liddell, Sapp, Zivley, and Laboon

Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology, Gerald J. Pels

Georgia Journal of International & Comparative Law

No abstract provided.


Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne 2015 University of Georgia School of Law

Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne

Georgia Journal of International & Comparative Law

No abstract provided.


Disc To Fsc: A Small Business Alternative?, Scott J. Klosinski 2015 University of Georgia School of Law

Disc To Fsc: A Small Business Alternative?, Scott J. Klosinski

Georgia Journal of International & Comparative Law

No abstract provided.


Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed, Phil Conner 2015 University of Georgia School of Law

Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed, Phil Conner

Georgia Journal of International & Comparative Law

No abstract provided.


Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth 2015 University of Georgia School of Law

Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth

Georgia Journal of International & Comparative Law

No abstract provided.


New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers 2015 Hansell & Post

New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers

Georgia Journal of International & Comparative Law

No abstract provided.


A Whole New World: Income Tax Considerations Of The Bitcoin Economy, Benjamin W. Akins JD, LLM, Jennifer L. Chapman JD, CPA, Jason M. Gordon JD, MBA 2015 Georgia Gwinnett College

A Whole New World: Income Tax Considerations Of The Bitcoin Economy, Benjamin W. Akins Jd, Llm, Jennifer L. Chapman Jd, Cpa, Jason M. Gordon Jd, Mba

Benjamin W. Akins

Bitcoin is a virtual, cryptocurrency growing rapidly in influence throughout the world. Numerous characteristics associated with the bitcoin system, including low transaction costs and greater user privacy, make it appealing as a medium of electronic payment. The number of users of bitcoin, including merchants accepting the currency as a form of payment, has grown considerably in recent years. Estimates indicate that there are more than 60,000 active bitcoin users as of September 2012, with nearly 11 million bitcoins in existence. According to the latest estimates, bitcoin market capitalization is roughly $9 billion. The growth of bitcoin as an accepted ...


Definitions, Religion, And Free Exercise Guarantees, Mark Strasser 2015 Capital University Law School

Definitions, Religion, And Free Exercise Guarantees, Mark Strasser

Mark Strasser

The First Amendment to the United States Constitution protects the free exercise of religion. Non-religious practices do not receive those same protections, which makes the ability to distinguish between religious and non-religious practices important. Regrettably, members of the Court have been unable to agree about how to distinguish the religious from the non-religious—sometimes, the implicit criteria focus on the sincerity of the beliefs, sometimes the strength of the beliefs or the role that they play in an individual’s life, and sometimes the kind of beliefs. In short, the Court has virtually guaranteed an incoherent jurisprudence by sending contradictory ...


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