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A New Deal For Europe? The Commerce Clause As The Solution To Tax Discrimination And Double Taxation In The European Union, Charles Edward Andrew Lincoln IV 2018 Pepperdine University

A New Deal For Europe? The Commerce Clause As The Solution To Tax Discrimination And Double Taxation In The European Union, Charles Edward Andrew Lincoln Iv

The Journal of Business, Entrepreneurship & the Law

No abstract provided.


U.S. Tax Treatment Of Australian Superannuation, John A. Castro 2018 University of Nevada, Las Vegas -- William S. Boyd School of Law

U.S. Tax Treatment Of Australian Superannuation, John A. Castro

Nevada Law Journal Forum

The Organization for Economic Cooperation and Development (OECD) estimates than more than 100,000 Australian citizens are living and working in the U.S. Those Australian nationals almost certainly have some sort of Superannuation Fund, which is a state-mandated occupational pension scheme in Australia. The problem is that nearly every accounting firm in the U.S. is treating Australian Superannuation as a taxable foreign grantor trust. This presents a serious issue since the funds within Superannuation Funds are completely inaccessible until retirement, disability, or death. For an Australian national living in the U.S., this would result in immediate U ...


Tax Compliance In A Decentralizing Economy, Manoj Viswanathan 2018 University of California Hastings College of Law

Tax Compliance In A Decentralizing Economy, Manoj Viswanathan

Georgia State University Law Review

Tax compliance in the United States has long relied on information from centralized intermediaries—the financial institutions,employers, and brokers that help ensure income is reported and taxes are paid. Yet while the IRS remains tied to these centralized entities,consumers and businesses are not. New technologies, such as sharing economy platforms (companies such as Airbnb, Uber, and Instacart)and the blockchain (the platform on which various cryptocurrencies are based) are providing new, decentralized options for exchanging goods and services.

Without legislative and agency intervention, these technologies pose a critical threat to the reporting system underlying domestic and international tax ...


Transparency And Disclosure, Diane Ring 2018 Boston College Law School

Transparency And Disclosure, Diane Ring

Diane M. Ring

Without a stable and adequate tax base, countries lose the financial capacity to provide the infrastructure, social services and development opportunities important to their citizens. In response, the G20 and the Organisation for Economic Co-operation and Development (OECD) organized the project on Base Erosion and Profit Shifting (BEPS). Much of the project has been focused on substantive law — the rules and practices that can allow the tax base of a country to be eroded and profits to be shifted out of the country. But the project recognizes that improved substantive tax rules alone are not sufficient to guarantee the tax ...


The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018, 2018 San Jose State University

The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding 2018 San Jose State University

The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding

The Contemporary Tax Journal

No abstract provided.


Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li 2018 San Jose State University

Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li

The Contemporary Tax Journal

No abstract provided.


Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017, Shimiao Gong, Xiaotong Stella Li, Ling Wei, Pingrong Xue 2018 San Jose State University

Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017, Shimiao Gong, Xiaotong Stella Li, Ling Wei, Pingrong Xue

The Contemporary Tax Journal

No abstract provided.


Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017, Veena Hemachandran, Katrina Jodrey, George (Peixuan) Liu, Leigh Ann Moore 2018 San Jose State University

Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017, Veena Hemachandran, Katrina Jodrey, George (Peixuan) Liu, Leigh Ann Moore

The Contemporary Tax Journal

No abstract provided.


Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., CPA, Benjamin George Ph.D. 2018 University of North Texas

Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.

The Contemporary Tax Journal

No abstract provided.


Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail 2018 Texas A&M University School of Law

Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail

Texas A&M Law Review

In early 2016, the International Consortium of Investigative Journalists released a report detailing thousands of leaked documents demonstrating how a Panamanian law firm had, for years, helped wealthy clients conceal their financial activities through the use of offshore shell companies. The Panama Papers, as the leaked documents came to be known, directed renewed attention at the use of shell companies. Shell companies are used by the world’s wealthy and powerful to lower their taxes, but are also used by tax evaders, criminal organizations, and terrorists. While much of the renewed attention has been directed at offshore tax havens such ...


The Dragon And The Eagle: Reforming China’S Securities Ipo Laws In The U.S. Model, Pros And Cons, Stuart R. Cohn, Miao Yinzhi 2018 Levin College of Law, University of Florida

The Dragon And The Eagle: Reforming China’S Securities Ipo Laws In The U.S. Model, Pros And Cons, Stuart R. Cohn, Miao Yinzhi

Washington University Global Studies Law Review

China is about to undergo a major reform of its securities offering and listing processes. Since the inception of China’s securities market in the early 1990s, the government has exercised tight control to determine which companies will be allowed to engage in initial public offerings and become listed on a national exchange. The system has led to both corruption and favoritism and has blocked numerable companies from access to capital markets. With the ascension in 2013 of Xi Jinping and Li Keqiang as the heads of the Chinese Communist Party and Premier, the government adopted reform of the market ...


Innovative Approach To Anti-Beps And The Coherence Of International Tax Law, Haiyan Xu 2018 University of Michigan Law School

Innovative Approach To Anti-Beps And The Coherence Of International Tax Law, Haiyan Xu

SJD Dissertations

This dissertation is comprised of three articles:

  • Avi-Yonah, Reuven,. co-author. "Evaluating BEPS: A Reconsideration of the Benefits Principle and Proposal for UN Oversight." H. Xu, co-author. Harv. Bus. L. Rev. 6, no. 2 (2016): 185-238
  • Reuven S. Avi-Yonah & Haiyan Xu, A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits, 39 Mich. J. Int'l L. 155 (2018).
  • Avi-Yonah, Reuven S. "China and BEPS." Haiyan Xu, co-author. Laws 7, no. 1 (2018): 4-30.


The Offshore Tax Enforcement Dragnet, Shu-Yi Oei 2018 Boston College Law School

The Offshore Tax Enforcement Dragnet, Shu-Yi Oei

Boston College Law School Faculty Papers

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore financial information by financial institutions and taxpayers. Yet, while these initiatives help catch willful tax cheats, they have also adversely affected immigrants, Americans living abroad, and “accidental Americans.”

This Article critiques the United States’ offshore tax enforcement initiatives, such as the Foreign Account Tax Compliant Act and the Internal Revenue Service’s offshore voluntary disclosure programs. It argues ...


China And Beps, Reuven S. Avi-Yonah, Haiyan Xu 2018 University of Michigan Law School

China And Beps, Reuven S. Avi-Yonah, Haiyan Xu

Articles

This article provides an overview of China’s reaction to the G20/OECD Base Erosion and Profit Shifting (BEPS) project. From 2013 to 2015, the OECD developed a series of actions designed to address BEPS activities by multinational enterprises, culminating in a final report of 15 action steps. The article reviews and explains China’s reaction to the BEPS project and its actions in detail, with a particular focus on transfer pricing issues. It shows that China has actively participated in both developing and implementing the BEPS project. The article further suggests that in the post-BEPS era, China is expected ...


Special International Zones In Practice And Theory, Tom W. Bell 2017 Selected Works

Special International Zones In Practice And Theory, Tom W. Bell

Tom W. Bell

The French Republic had a problem. Foreign nationals had flown into the Roissy-Charles de Gaulle Airport near Paris and claimed the right to stay as refugees seeking asylum. Unwilling to have the supposed refugees imposed upon it, France resolved to process their claims without letting them into the country. How? By keeping them in the airport’s international transit zone—the area between the exit doors of airplanes arriving from abroad and the far side of customs and immigration clearance. This split border allowed France to summarily process and (typically) deport the foreigners while keeping them outside the country’s ...


Tax In The World Of Antitrust Enforcement: European Commission’S State Aid Investigations Into Eu Member States’ Tax Rulings, Nina Hrushko 2017 Brooklyn Law School

Tax In The World Of Antitrust Enforcement: European Commission’S State Aid Investigations Into Eu Member States’ Tax Rulings, Nina Hrushko

Brooklyn Journal of International Law

In August 2016, after a two-year investigation, the European Commission issued a negative State aid ruling against Ireland, finding that the country had provided illegal tax benefits to Apple Inc. and requesting the government to collect €13 billion in retroactive taxes from the company. This decision sparked a heated debate around the globe about the European Commission’s authority to interfere into the individual EU Member States’ fiscal policies and order retroactive tax recoveries. This Note explores the application of EU State aid rules to tax laws and, in particular, EU Member States’ tax rulings, and discusses the European Commission ...


A Vatcoin Proposal Following On The 2017 Eu Vat Proposals - Mtic, Vatcoin, And Blockchain, Richard Thompson Ainsworth, Musaad Alwohaibi, Michael Cheetham, Camille V. Tirand 2017 Boston University School of Law

A Vatcoin Proposal Following On The 2017 Eu Vat Proposals - Mtic, Vatcoin, And Blockchain, Richard Thompson Ainsworth, Musaad Alwohaibi, Michael Cheetham, Camille V. Tirand

Faculty Scholarship

The following proposal for an EU VATCoin was presented at the Digital Tax Transformations Conference, December 18 & 19, 2017 in Vienna, Austria at WU Global Tax Policy Center (WU GTPC) at the Institute for Austrian and International Tax Law of Vienna University of Business and Economics.

The EU Commission has proposed “far-reaching reforms” to solve some of the fraud in the EU VAT. It hopes to capture €50 billion lost annually to MTIC fraud in goods. It hopes to do this without addressing tradable services, a MTIC mutation which by all accounts is running strong.

Fortunately, the Commission is open ...


Taxing Systemic Risk, Eric D. Chason 2017 William & Mary Law School

Taxing Systemic Risk, Eric D. Chason

The University of New Hampshire Law Review

A tax on the harmful elements of finance—a tax on systemic risk—would raise revenue and also lower the likelihood of future crisis. Financial institutions, which pay the tax, would try to minimize its cost by lowering their systemic risk. In theory, a tax on systemic risk is perfect policy. In practice, however, this perfect policy is unattainable. Tax laws need clear definitions to be administrable. Our current understanding of systemic risk is too abstract and too metaphorical to serve as a target for taxation.

Despite the absence of a clear definition of systemic risk, academics and policy makers ...


Corporate Migrations And Tax Transparency And Disclosure, Diane M. Ring 2017 Boston College Law School

Corporate Migrations And Tax Transparency And Disclosure, Diane M. Ring

Boston College Law School Faculty Papers

Migration, broadly defined, characterizes the movement of peoples and businesses across borders. The latter part of the 20th century saw notable business expansion across borders spurred by currency, capital, and investment restrictions and by the increased ability to manage global activities through technology and communications. Twenty plus years into this business globalization, we have witnessed the dramatic rise of transparency and disclosure rules and regimes. These regimes, which have dominated much of global international tax reform, include: (1) country-by-country reporting of tax information, (2) automatic exchange of tax rulings among jurisdictions, and (3) disclosure of beneficial ownership of entities. In ...


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