Law Commons^™

Notional Generosity, Josh Eagle

Josh Eagle

This article explores a phenomenon that might be called “gift-form generosity”: people earning similar amounts of income are more willing to part with a dollar’s worth of one kind of property than another. Among all income groups, the form of property with which charitable donors are most willing to part is the “conservation easement.” Data show, for example, that the average charitable easement donation is more than 100 times greater in value than the total, annual charitable contribution made by the average American taxpayer. Why are donors so willing to part with conservation easements? The answer may lie in donors’ …

Panelist, Oecd Conference On Intangibles, Hugh Ault

Hugh J. Ault

No abstract provided.

Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault

Hugh J. Ault

No abstract provided.

Transfer Pricing, Hugh Ault

Hugh J. Ault

Chaired meeting of 45 governmental and academic specialist

Panelist, The International Network For Tax Research And The American Journal Of Comparative, Conference On "Comparative Tax Law: Theory And Practice, Hugh Ault

Hugh J. Ault

No abstract provided.

Guidance On A Topic That Spans Practice Areas And Professions (Reviewing P. Garth Gartrell And Steven P. Lapidus, Executive Compensation For Emerging Growth Companies (2008)), Michael Hussey

Michael Hussey

No abstract provided.

Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault

Hugh J. Ault

No abstract provided.

Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault

Hugh J. Ault

No abstract provided.

2008 Oecd Model: The New Arbitration Provision, Hugh Ault

Hugh J. Ault

New Art. 25(5), added to Art. 25 (Mutual agreement procedure) of the OECD Model as part of the 2008 Update, provides for the mandatory arbitration of unresolved issues arising in the course of a mutual agreement procedure. This article first examines the various factors that led to the adoption of Art. 25(5) and the stages of its development by the OECD. The article then discusses some technical aspects of the new arbitration provision, including the Sample Mutual Agreement setting out some procedural rules, which is attached as an Annex to Art. 25.

Session Chair, Oecd Advisory Group For Co-Operation With Non-Oecd Countries, Hugh Ault

Hugh J. Ault

No abstract provided.

Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault

Hugh J. Ault

No abstract provided.

Reflections On The Role Of The Oecd In Developing International Tax Norms, Hugh Ault

Hugh J. Ault

On September 8–9, 2008, the Organisation for Economic Cooperation and Development (“OECD”) held a Special Conference commemorating the 50th Anniversary of the OECD Model Tax Convention (“Model Convention” or “Model”). The Conference was attended by over 650 participants from the private sector and the government, representing over 100 countries. Both the level of participation and the geographical diversity represented at the conference would seem concrete evidence of the perceived importance of the role of the OECD in developing international tax norms. In his remarks opening the conference, the OECD Secretary General noted that the success of the OECD Model was …

Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda

Hugh J. Ault

In a practice article, Mitsuhiro Honda and Hugh J. Ault comment on a Tokyo High Court ruling that held that Japan's controlled foreign corporation rules are consistent with article 7(1) of the Japan-Singapore tax treaty.

Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault

Hugh J. Ault

No abstract provided.

Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault

Hugh J. Ault

No abstract provided.

Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault

Hugh J. Ault

No abstract provided.

Editorial, Federal Tax Reform Has Gone By The Wayside, Michael Hussey

Michael Hussey

No abstract provided.

Improving The Resolution Of International Tax Disputes, Hugh Ault

Hugh J. Ault

The dramatic increase in international trade and investments and related phenomena under the general heading of Globalization have multiplied the situations in which international tax disputes can arise, both between taxpayers and governments but also, and in some ways, more importantly, between governments themselves. These disputes may involve transfer pricing issues, differing income characterization rules, disagreement about the existence of a permanent establishment, or more generally, diverging views on the appropriate exercise of potential taxing rights by the source country jurisdiction and the corresponding obligation of the residence country to provide double tax relief. In the current circumstances, it seems …

Toxic Diversity: Race, Gender And Law Talk In America, Dan Subotnik

Dan Subotnik

Toxic Diversity offers an invigorating view of race, gender, and law in America. Analyzing the work of preeminent legal scholars such as Patricia Williams, Derrick Bell, Lani Guinier, and Richard Delgado, Dan Subotnik argues that race and gender theorists poison our social and intellectual environment by almost deliberately misinterpreting racial interaction and data and turning white males into victimizers. Far from energizing women and minorities, Subotnik concludes, theorists divert their energies from implementing America's social justice agenda.

Insisting, in the words of James Baldwin, that “not everything that is faced can be changed, but nothing can be changed until it …

Review Of Foundations Of International Income Taxation, By Michael Graetz, Hugh Ault

Hugh J. Ault

No abstract provided.

U.S. Exemption/Territorial System Vs. Credit-Based System, Hugh Ault

Hugh J. Ault

No abstract provided.

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

Hugh J. Ault

No abstract provided.

U.S. Corporate Taxation Reform From An International Perspective, Hugh Ault

Hugh J. Ault

No abstract provided.

Use Of Life Insurance In Nonqualified Deferred Compensation Planning, Michael Hussey, William Drennan, Michael Goldstein

Michael Hussey

No abstract provided.

Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault

Hugh J. Ault

No abstract provided.

Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault

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 1998 Supplement: Federal Income Taxation of Business Organizations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; Special 1997 Legislative Supplement: Federal Income Taxation of Business Organizations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.

Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons

Hugh J. Ault

Supplemented by 1998 Supplement: Federal Income Taxation of Partnerships and S Corporations. 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; 1997 Supplement to Federal Income Taxation of Partnerships and S Corporations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.

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.

The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault

Hugh J. Ault

No abstract provided.