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768 full-text articles. Page 6 of 22.

Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson 2015 University of Georgia School of Law

Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson

Georgia Journal of International & Comparative Law

No abstract provided.


Destination-Based Cash-Flow Taxation: A Critical Appraisal, Wei Cui 2015 University of Michigan - Ann Arbor

Destination-Based Cash-Flow Taxation: A Critical Appraisal, Wei Cui

Wei Cui

This Article offers the first comprehensive appraisal in both the legal and economic literatures of proposals for adopting destination-based cash flow taxation (DCFT) of multinational corporations. The DCFT was a key recommendation for reforming corporate taxation in the U.K., and has subsequently attracted wide attention as a way to fundamentally reform international taxation in the U.S., Europe and elsewhere. The core intuition of the DCFT is to tax profits earned by mobile capital by reference to immobile factors. I distinguish three versions of the DCFT for implementing this intuition: 1. formulary apportionment of business profits by reference to ...


Tax Debt Relief - Settle Your Debt With The Irs, Christa Jocelyn 2015 University of California - Berkeley

Tax Debt Relief - Settle Your Debt With The Irs, Christa Jocelyn

Christa Jocelyn

The Complete IRS Tax Relief Guide to solve your tax troubles and help you decide which solution is right for you.


Is The Real Estate Investment And Jobs Act A Good Idea?, Willard Taylor 2015 NYU Law School

Is The Real Estate Investment And Jobs Act A Good Idea?, Willard Taylor

Willard B. Taylor

The Real Estate Investment and Jobs Act of 2015 would significantly relax the rules of the 1980 Foreign Investment in Real Property Tax Act for investments in U.S. real property made through U.S. real estate investment trusts and, in the House version, would simply exempt from FIRPTA investments by foreign pension funds. Taylor discusses the bills and argues that it would make more sense to repeal FIRPTA (including the U.S. real property holding corporation rules) and then seek to achieve parity of treatment for investments in U.S. real property by foreign persons that are made directly ...


Sales Tax And Cloud Computing In India, Khagesh Gautam 2015 O.P. Jindal Global University

Sales Tax And Cloud Computing In India, Khagesh Gautam

Khagesh Gautam

This Article, the first of its kind, addresses the question of imposition of sales tax on Cloud computing transactions in India. Several industry estimates show that the Cloud computing market is growing in India and is poised to grow further. However, the question of how to tax these transactions remains to be addressed. This Article engages with this question, albeit only in the context of sales tax. The Indian Constitution lays down, in elaborate detail, the taxes that can exclusively be levied by the Union Parliament and those that can exclusively be levied by the State Legislatures. Sales tax on ...


The Eu Export Tax: Impact On U.S. Markets, William H. Meyers, Steven L. Elmore 2015 Iowa State University

The Eu Export Tax: Impact On U.S. Markets, William H. Meyers, Steven L. Elmore

Iowa Ag Review

ln response to high world grain prices, the European Union (EU) introduced wheat export taxes in November 1995 for the first time in more than a decade. Normally, the EU offers export subsidies to make up the difference between their high internal grain prices and world market prices. However, EU internal support prices have been reduced over the last three years as a result of policy reforms. Recent high world grain prices have exceeded the EU support prices since early in the 1995/96 crop year. Rather than let internal prices follow world market prices upward, the EU decided to ...


What The Beps, Yariv Brauner 2015 University of Florida Levin College of Law

What The Beps, Yariv Brauner

Yariv Brauner

Unprecedented attention to aggressive international tax planning has shaken the earth under the most powerful players in the world of international tax policy design. The media exposure of what Bloomberg's calls “The Great Corporate Tax Dodge,” combined with the ever-growing discontent of civil society with the magnitude of contribution of the largest multinational enterprises to the society within which they operate, has recently forced the politicians to take action. Leaders of the strongest world economies demanded a revision of the rules of the international tax regime that would generate more revenues for their challenged coffers and would restore public ...


Credit Vs. Exemption: A Comparative Study Of Double Tax Relief In The United States And Japan, Lawrence Lokken, Yoshimi Kitamura 2015 Selected Works

Credit Vs. Exemption: A Comparative Study Of Double Tax Relief In The United States And Japan, Lawrence Lokken, Yoshimi Kitamura

Lawrence Lokken

The overriding issue in international taxation is the problem of double taxation. Under the tax laws of most countries, income may be taxed on the basis of either residence or source. That is, a country may tax residents of the country on worldwide income and may tax nonresidents on income from sources within the country. Thus, if a resident of one country has income from a business activity or investment in another country, the person may be taxed on the income on a residence basis by its home country and on a source basis in the other country. Most countries ...


The Contemporary Tax Journal Volume 5, No. 1 – Spring/Summer 2015, 2015 San Jose State University

The Contemporary Tax Journal Volume 5, No. 1 – Spring/Summer 2015

The Contemporary Tax Journal

No abstract provided.


Offshore Web-Based Gambling Accounts Are Subject To Fbar, Min (Megan) K. Park 2015 San Jose State University

Offshore Web-Based Gambling Accounts Are Subject To Fbar, Min (Megan) K. Park

The Contemporary Tax Journal

No abstract provided.


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 Law and Economics 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 ...


Taxing Potential Community Members' Foreign Source Income, Daniel Shaviro 2015 NYU School of Law

Taxing Potential Community Members' Foreign Source Income, Daniel Shaviro

New York University Law and Economics Working Papers

Recent years have witnessed rising debate, on both sides of the Atlantic, regarding how to define the category of individuals whom a given country classifies as domestic taxpayers, and who thus may be taxable on their foreign source income (FSI) even if they live abroad. While the United States rules focus distinctively on citizenship, the broader issue is better viewed as pertaining to the taxation of “potential community members” (PCMs) – that is, all those who plausibly might be viewed as members of the home community.

This paper makes two main points regarding the taxation of PCMs on their FSI. First ...


The Use Of Oecd Commentaries As Interpretative Aids - The Static/Ambulatory-Approaches Debate Considered From The Perspective Of International Law, Maria Hilling, Ulf Linderfalk 2015 Lund University

The Use Of Oecd Commentaries As Interpretative Aids - The Static/Ambulatory-Approaches Debate Considered From The Perspective Of International Law, Maria Hilling, Ulf Linderfalk

Maria Hilling

Since many years, international tax law experts debate the relevance of changes to OECD Commentaries for the purpose of the interpretation of previously concluded tax treaties. Although, generally, most experts seem averse to the idea of an ambulatory approach to the usage of OECD Commentaries, they are reluctant to exclude this idea altogether. Such a position raises an important issue of justification: When exactly should the ambulatory approach be taken? As argued in this essay, the proper answer to this question depends on the particular rule of interpretation justifying the usage of OECD Commentaries in particular cases. If Commentaries are ...


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.


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