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Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Hugh J. Ault
In this Article, Professor Ault begins with an examination of the evolution of treaty principles for the allocation of and restrictions on international taxing jurisdiction. He then focuses on how economically based principles dealing with the taxation of international income affect treaty policy and presents the basic structural provisions involving the taxation of foreign income and foreign investors that emerge from domestically enacted or proposed integration systems. The technical aspects of the actual treaty practices that have been implemented with respect to integration systems are then related to the theoretical discussion. Professor Ault concludes with an examination of the implications …
Who Is Making International Tax Policy? International Organizations As Power Players In A High Stakes World, Diane M. Ring
Who Is Making International Tax Policy? International Organizations As Power Players In A High Stakes World, Diane M. Ring
Diane M. Ring
Who makes international tax policy in today’s world? Certainly no single body possesses that power - there is no global tax authority, and states are not capable of achieving all of their international tax policy goals on a unilateral basis. The development of international tax policy is an interactive and dynamic process that involves a wide range of players, most of whom can be characterized as international organizations. Their roles, goals, tools and influence vary by organization and by issue, but their net impact on tax policy is undeniable. If we are to better understand how tax policy is formed, …