Law Commons^™

Taxing Indirect Transfers: Improving An Instrument For Stemming Tax And Legal Base Erosion, Wei Cui

Wei Cui

Numerous countries (e.g. Canada, Australia and Japan) tax foreigners on the gains realized on transfers of interests in foreign entities that invest directly or indirectly in real estates in these countries. In the last few years, actions taken by tax authorities in India, China, Brazil, Indonesia and other non-OECD countries have highlighted the possibility of taxing a broader range of “indirect share transfers” by foreigners. This Article argues taxing indirect transfers can have vital policy significance in countries where foreign inbound investments are actively traded in offshore markets: it not only deters tax avoidance, but may also stanch “legal base …

Taxing Social Enterprise, Lloyd Hitoshi Mayer, Joseph R. Ganahl

Lloyd Hitoshi Mayer

The fairly strict divide in the United States between for-profit and nonprofit forms presents a quandary for many entrepreneurs who want to combine doing good with doing well. On the one hand, for-profits offer great flexibility and access to capital and so attract entrepreneurs who would like to take advantage of the ability of for-profits to scale up rapidly to meet growing demand. At the same time, however, for-profit forms also limit entrepreneurs’ ability to engage in philanthropy, due to the fiduciary duties managers owe to the equity holders. On the other hand, nonprofits offer their founders the freedom to …

Limited Liability Entities: State By State Guide To Llcs, Llps And Lps, Bradley Borden, Robert Rhee

Robert Rhee

To make your research more efficient Wolters Kluwer Law & Business is combining the former State Limited Liability Company and Partnership Laws and State Limited Partnership Laws title into one new resource entitled Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs. Our new authors are Bradley Borden and Robert Rhee (see About the Authors). Volume 1, the first installment of Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs, provides a comprehensive overview of limited liability entities. It begins with a detailed review of the history and evolution of limited liability entities. It …

Fiscal Federalism In Chinese Taxation, Wei Cui

Wei Cui

The legal debate about the decentralization of taxing power in China has mainly centered around a directive issued by the State Council at the end of 1993, which directive, at the same time as launching the well-known and widely-discussed tax reform of 1994, announced that legislative power regarding taxation would be reserved exclusively for the central government. This directive has no constitutional basis, and its subsequent statutory incarnations are all either incomplete or ambiguous. Moreover, in the adoption of tax regulations for many types of taxes, there have been numerous deviations from this principle of centralization, and the bearing of …

Tax And Terrorism: A New Partnership?, Michelle Gallant

Michelle Gallant

The global chase for terrorist assets has shed light on a link between tax and terrorism. Tax havens have been associated with terrorist finance, identified as potential centres for filtrating terrorist assets and for enabling the cross-border movement of the resources destined for terrorist enterprises. Complex multi-jurisdictional financial transactions have become the venues for the merger of terrorist finance with other mobile capital, its criminally ordained purpose hidden midst the convolutions of international tax and related transactions.

To many the mechanics of tax is an inaccessible subject. It consists of a complex matrix of laws best left to the professional …

Taxation Of Income From Mobil Capital: Some Recent International Developments, Hugh Ault

Hugh J. Ault

No abstract provided.

Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons

Hugh J. Ault

Supplemented by 1995 Supplement to Federal Income Taxation, Cases and Materials. 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1995; 1997 Supplement to Federal Income Taxation: Cases and Materials, 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.

Federal Income Tax Project: International Aspects Of United States Income Taxation Ii: Proposals Of The American Law Institute On United States Income Tax Treaties, Hugh Ault, David Tillinghast

Hugh J. Ault

No abstract provided.

Federal Income Taxation Of Business Organizations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons

Hugh J. Ault

Supplemented by 1991 Supplement to Federal Income Taxation of Business Organizations, by McDaniel, Ault, McMahon, and Simmons. Westbury, NY: Foundation Press, 1991; 1992 Supplement to Federal Income Taxation of Business Organizations, by McDaniel, Ault, McMahon, and Simmons. Westbury, N.Y.: Foundation Press, 1992; 1994 Supplement to Federal Income Taxation of Business Organizations, by McDaniel, Ault, McMahon, and Simmons. Westbury, NY: Foundation Press, 1994; 1995 Supplement to Federal Income Taxation of Business Organizations, by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1995.

Family Taxation In The United States: The Choice Of Taxable Unit, Hugh Ault

Hugh J. Ault

No abstract provided.

United Kingdom: Tax Avoidance And The Courts, Hugh Ault, Philip Kaplan

Hugh J. Ault

No abstract provided.

United States: More On Unitary Taxation Of Multinational Groups, Hugh Ault

Hugh J. Ault

No abstract provided.

Subpart F À La Française [French Attitude To Tax Havens], Hugh Ault, Philip Kaplan

Hugh J. Ault

No abstract provided.

Nondiscrimination Clauses And State Taxation, Hugh Ault

Hugh J. Ault

No abstract provided.

Steuern In Den Usa, Hugh Ault

Hugh J. Ault

No abstract provided.

Federal Wealth Transfer Taxation: Cases And Materials, Hugh Ault, Stanley Surrey, William Warren, Paul Mcdaniel

Hugh J. Ault

(Volume 1 supplemented by 1975 Supplement to Federal Income Taxation: Cases and Materials, volume 1, by Surrey, Warren, McDaniel, and Ault. Mineola, NY: Foundation Press, 1975;1977 Supplement to Federal Income Taxation: Cases and Materials, volume 1, by Surrey, Warren, McDaniel, and Ault. Mineola, NY: Foundation Press, 1977; 1979 Supplement to Federal Income Taxation: Cases and Materials, volume 1, by Surrey, Warren, McDaniel, and Ault. Mineola, NY: Foundation Press, 1979; 1982 Supplement to Federal Income Taxation: Cases and Materials, volume 1, by Surrey, Warren, McDaniel, and Ault. Mineola, NY: Foundation Press, 1982; 1983 Supplement to Federal Income Taxation: Cases and Materials, …