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Full-Text Articles in Law
Summaries: Tax Law, Blaise Curet
Summaries: Tax Law, Blaise Curet
Golden Gate University Law Review
No abstract provided.
Tax Law, Laurie Ann Hedrich
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Golden Gate University Law Review
No abstract provided.
Reply To Becker And Fuest, James R. Hines Jr.
Reply To Becker And Fuest, James R. Hines Jr.
Articles
It is an understatement to say that the appropriate taxation of foreign business income is a controversial and potentially confusing topic. One of the mysteries of international taxation has been that the prescriptions of what, until recently, was the accepted academic wisdom differs so sharply from widespread international practice. In an important contribution, Richman (1963) noted that a home government confronted with the choice of where it would prefer one of its resident taxpayers to allocate a single unit of capital would weigh the after-foreign-tax return from investing abroad against the pre-tax return from investing at home. From this observation, …
Foreign Income And Domestic Deductions, James R. Hines Jr.
Foreign Income And Domestic Deductions, James R. Hines Jr.
Articles
To what extent should taxpayers deduct expenses incurred domestically that contribute to foreign income production? It is widely believed that if the home country does not tax foreign income, then it also should not permit deductions for that portion of domestic expenses attributable to earning foreign income. This prescription is, however, inconsistent with the decision to exempt foreign income from taxation in the first place. The paper shows that, for any system of taxing foreign income, the consistent and efficient treatment is to permit domestic expense deductions for all expenses incurred domestically. This differs from the current U.S. regime, under …
"Expense" Deductions On "Personal" Gross Income, Deborah A. Geier
"Expense" Deductions On "Personal" Gross Income, Deborah A. Geier
Law Faculty Articles and Essays
Prof. Deborah A. Geier responds to Tom Daley's letter on the taxation of contingent attorney fees.