Open Access. Powered by Scholars. Published by Universities.®
- Institution
- Publication Type
Articles 1 - 2 of 2
Full-Text Articles in Law
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael S. Kirsch
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael S. Kirsch
Michael Kirsch
Over the past decade, a number of scholars have addressed the United States’ continuing use of citizenship as a jurisdictional basis upon which to tax the foreign-source income of individuals in the modern international setting. Some writers, including myself, have defended this citizenship-based taxation (“CBT”), while others have rejected it and proposed some form of residence-based taxation (“RBT”) for citizens.This Article considers the competing normative arguments raised in this context, and attempts to distill the strengths and weaknesses of each. In so doing, it attempts to highlight the most important factors upon which the debate hinges, and illustrates the importance …
Transfer Pricing Challenges In The Cloud, Orly Mazur
Transfer Pricing Challenges In The Cloud, Orly Mazur
Faculty Journal Articles and Book Chapters
Cloud computing - the provision of information technology resources in a virtual environment - 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 As a result, taxpayers and tax administrations confront significant tax challenges in applying outdated tax principles to this new environment.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 in which jurisdiction …