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The Implications For Australian Businesses Of Recent Developments In Us State Taxation Of Online Cross-Border Sales, Walter Hellerstein

Popular Media

Although there is no broad-based national consumption tax in the United States, 45 of the 50 states and the District of Columbia, as well as thousands of local jurisdictions, impose general retail sales taxes. For the twelve-month period ending in September 2020, sales taxes yielded USD 333 billion or 31.1 per cent of state tax revenues.

The US Supreme Court’s 2018 decision in South Dakota v. Wayfair, Inc. dramatically expanded the US states’ power to require remote suppliers to collect taxes on in-bound sales to local consumers. The decision repudiated the pre-existing, judicially created constitutional rule limiting the states’ …

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.

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.

Current Developments In Procedures For The Resolution Of International Tax Disputes, Hugh Ault

Hugh J. Ault

No abstract provided.

Introduction To United States International Taxation, Hugh Ault, James Repetti, Paul Mcdaniel

Hugh J. Ault

The 2005 edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on ten specific aspects of the subject matter: -general aspects of the corporation income tax, the individual income tax, the …

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 …

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.

Arbitration In International Tax Matters: Some Structural Issues, Hugh Ault

Hugh J. Ault

No abstract provided.

The Importance Of International Cooperation In Forging Tax Policy, Hugh J. Ault

Hugh J. Ault

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.

Steuervereinfachung Im Internationalen Vergleich, Hugh Ault

Hugh J. Ault

No abstract provided.

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

Hugh J. Ault

No abstract provided.

The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault

Hugh J. Ault

An updated version appears inIntertax 4 (April 1994): 144-148.

The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault

Hugh J. Ault

No abstract provided.

Commentary [On `The Foreign Tax Credit And Its Critics,' By Charles I. Kingson, Hugh Ault

Hugh J. Ault

No abstract provided.

Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford

Hugh J. Ault

No abstract provided.

Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford

Hugh J. Ault

No abstract provided.

Foreign Tax Provisions Of H.R. 3838, Hugh Ault, Stanford Ross, Gerard Brannon

Hugh J. Ault

No abstract provided.

The Unitary Tax Controversy: Federalism, Treaties And International Tax Relationships, Hugh Ault

Hugh J. Ault

No abstract provided.

Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel

Hugh J. Ault

Introduction à la Fiscalité Internationale Américaine, translated by Arthur Young and Company, 1982.

Social Security Totalization Agreement With The Federal Republic Of Germany, Hugh Ault

Hugh J. Ault

No abstract provided.

The Effect Of Losses In One Country On The Income Tax Treatment In Another Country Of An Enterprise Or Of Associated Companies Engaged In International Activities, Hugh Ault, Donald Gerwig, Michael Henning

Hugh J. Ault

No abstract provided.

Möglichkeiten Und Grenzen Der Übertragung Von Einkunftsquellen Nach Amerikanischem Steuerrecht, Hugh Ault

Hugh J. Ault

No abstract provided.

Present Legislation And A Rational Structure For The Operation Of The Credit Mechanism, Hugh Ault

Hugh J. Ault

No abstract provided.

Lehre Und Forschung Im Steurrecht In Den Usa, Hugh Ault

Hugh J. Ault

No abstract provided.