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Recent Developments And Future Prospects Of The Common Market, Michael Waelbroeck 2016 University of Brussels

Recent Developments And Future Prospects Of The Common Market, Michael Waelbroeck

Georgia Journal of International & Comparative Law

No abstract provided.


Demanding Corporate Patriotism: A Regulatory Attempt To Curb International Corporate Inversions And Stop Tax Avoidance Schemes, David Khanjyan 2016 Pepperdine University

Demanding Corporate Patriotism: A Regulatory Attempt To Curb International Corporate Inversions And Stop Tax Avoidance Schemes, David Khanjyan

The Journal of Business, Entrepreneurship & the Law

No abstract provided.


Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd 2016 University of Georgia School of Law

Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd

Georgia Journal of International & Comparative Law

No abstract provided.


The Merits Of Tax Competition In A Globalized Economy, David Elkins 2016 Netanya College

The Merits Of Tax Competition In A Globalized Economy, David Elkins

Indiana Law Journal

Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member States and impedes their ability to provide essential services. Commentators have argued that unrestrained competition is driving tax rates on mobile sources of income to (or close to) zero, a process that jeopardizes the very existence of the welfare state, exacerbates problems of global poverty, and deprives developing countries of funds that they desperately ...


The Timing Of Tax Transparency, Joshua D. Blank 2016 NYU School of Law

The Timing Of Tax Transparency, Joshua D. Blank

New York University Law and Economics Working Papers

Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is ...


Transfer Pricing Challenges In The Cloud, Orly Mazur 2016 Southern Methodist University Dedman School of Law

Transfer Pricing Challenges In The Cloud, Orly Mazur

Boston College Law Review

Cloud computing has fundamentally changed how companies operate. Companies have quickly adapted by moving their businesses to the cloud, but international tax standards have failed to follow suit. As a result, taxpayers and tax administrations confront significant tax challenges in applying outdated tax principles to this new environment. One particular area that raises perplexing tax issues is the transfer pricing rules. The transfer pricing rules set forth the intercompany price a cloud service provider must charge an affiliate using its cloud services, which ultimately affects the determination of the jurisdiction in which the company’s profits are taxed. This Article ...


Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso 2016 College of William & Mary Law School

Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso

William & Mary Business Law Review

Currently, the concept of tax inversion is a major corporate phenomenon. In the United States, companies pay taxes on all earnings, whether or not they were accumulated here. With one of the highest corporate tax rates in the world, this is a major expense for U.S. corporations competing in the world market. While most companies simply deal with the tax burden, some U.S. corporations buy foreign companies and relocate the company headquarters to the acquisition’s home country. This corporate expatriation allows companies to avoid U.S. taxes on earnings in a number of ways. This Note will ...


The Meaning Of Capital In The Twenty-First Century, Edward J. McCaffery 2016 University of Southern California;California Institute of Tecnology

The Meaning Of Capital In The Twenty-First Century, Edward J. Mccaffery

University of Southern California Legal Studies Working Paper Series

America is on a path towards a level of both wealth and income inequality unparalleled in recorded history. Thomas Piketty’s Capital in the Twenty-First Century summarizes and conveys the work of Piketty and many co-authors, over many decades, looking at the structure of income and wealth inequality across many nations and centuries. This review essay builds on Piketty’s ambitions as well as his data, in order to put forth a better solution: one that accepts and even embraces the facts of unequal ownership of capital, but changes the social meaning of those facts to avoid the social harms ...


The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016, 2016 San Jose State University

The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.), 2016 San Jose State University

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

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja 2016 San Jose State University

The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja

The Contemporary Tax Journal

No abstract provided.


When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh 2016 San Jose State University

When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh

The Contemporary Tax Journal

No abstract provided.


Repeal The Alternative Minimum Tax, Branden Wilson 2016 San Jose State University

Repeal The Alternative Minimum Tax, Branden Wilson

The Contemporary Tax Journal

No abstract provided.


Analysis Of The Federal Estate Tax, Rachita Kothari 2016 San Jose State University

Analysis Of The Federal Estate Tax, Rachita Kothari

The Contemporary Tax Journal

No abstract provided.


A Constructive U.S. Counter To Eu State Aid Cases, Itai Grinberg 2016 Georgetown University Law Center

A Constructive U.S. Counter To Eu State Aid Cases, Itai Grinberg

Georgetown Law Faculty Publications and Other Works

U.S. Treasury officials and members of Congress from both parties have expressed concern that the European Commission’s current state aid investigations are disproportionately targeting U.S.-based multinational enterprises. At the same time, a Treasury official recently suggested in congressional testimony that there are limits to what Treasury can do beyond strongly expressing its concerns to the commission. In that testimony, Treasury’s representative hinted at two specific pressure points: whether the state aid investigations could undermine U.S. tax treaties with EU member states; and whether any assessments paid by the foreign subsidiaries of U.S. MNEs ...


From Avoiding ‘Double Taxation’ Yesterday To Avoiding ‘Double Non-Taxation’ Today: The Urgent Need For An International Tax Regime Based On Unitary Tax Principles, Zachée Pouga Tinhaga 2016 University of Michigan Law School

From Avoiding ‘Double Taxation’ Yesterday To Avoiding ‘Double Non-Taxation’ Today: The Urgent Need For An International Tax Regime Based On Unitary Tax Principles, Zachée Pouga Tinhaga

SJD Dissertations

The purpose of this Dissertation is to analyze the current ills of the international tax system with a special focus on developing countries, and to structure and present a Unitary Taxation System (“UT”) as a solution to the legitimate and multifaceted complaints about current international taxation of multinational companies (“MNEs”). The research aims at presenting a UT that would restore credibility in the international tax arena by providing fiscal predictability and certainty to MNEs, and ensuring appropriate taxation by all countries (specifically developing nations) of all “real” economic activity within their borders. Although this issue has been previously explored, there ...


Treaties In The Aftermath Of Beps, Yariv Brauner 2016 Brooklyn Law School

Treaties In The Aftermath Of Beps, Yariv Brauner

Brooklyn Journal of International Law

The article argues that, despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The challenges to the dominance of the OECD and the richest countries would likely be assuaged with marginal concessions, most or all of which not be affecting tax treaties. Yet, the article sees a silver lining in the non-substantive, structural, and instrumental outcomes of the BEPS project. It argues that even if unintended ...


Tax Treaties And The Taxation Of Services In The Absence Of Physical Presence, Michael S. Kirsch 2016 Brooklyn Law School

Tax Treaties And The Taxation Of Services In The Absence Of Physical Presence, Michael S. Kirsch

Brooklyn Journal of International Law

The increasing ability to deliver personal services electronically raises significant cross-border tax issues. In particular, given that the service provider need not be physically present in the would-be source country, significant questions arise as to the continued viability of tax treaty rules that focus on the service provider’s physical location. In response to these developments, proposed changes to the United Nations Model tax treaty have been approved that would allow source country taxation of technical services, even in the absence of the service provider’s physical presence. This article raises concerns about the broad scope of the proposed changes ...


When International Tax Agreements Fail At Home: A U.S. Example, Diane Ring 2016 Brooklyn Law School

When International Tax Agreements Fail At Home: A U.S. Example, Diane Ring

Brooklyn Journal of International Law

Over the past two and a half years, the international tax community has focused on the Base Erosion and Profit Shifting Project (BEPS project) undertaken by the Organisation for Economic Co-operation and Development (OECD) at the behest of the G20. According to the OECD, the resulting 2015 agreement involved the direct participation of more than sixty countries. An additional fifty-nine countries indirectly participated through regional dialogues. Furthermore, numerous international organizations are credited with participating in discussions and contributing to the resulting product. But, effective implementation of the BEPS agreement requires domestic action of various types—the domestic side of international ...


“Thinking Outside The (Tax) Treaty” Revisited, Adam H. Rosenzweig 2016 Brooklyn Law School

“Thinking Outside The (Tax) Treaty” Revisited, Adam H. Rosenzweig

Brooklyn Journal of International Law

The rise and development of “Base Erosion and Profit Shifting” project by the Organization for Economic Cooperation and Development (BEPS) provides an ideal opportunity to revisit the fundamental principles underlying the international tax regime and the bilateral tax treaty regime in particular. This is true because BEPS represents both an attempt to create a new, truly multinational consensus on international tax matters and a clear move away from the bilateral tax treaty as the primary form of international coordination. From this perspective, BEPS provides the perfect opportunity to revisit the role of a proposed dispute resolution mechanism for nontreaty member ...


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