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Full-Text Articles in Law

Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas Oct 2014

Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas

Georgia Journal of International & Comparative Law

No abstract provided.


Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah Dec 2000

Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah

Articles

This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.


A New Export Policy: The Foreign Sales Corporation And State Unitary Taxation Of Foreign Source Income, Reed D. Rubinstein Jan 1984

A New Export Policy: The Foreign Sales Corporation And State Unitary Taxation Of Foreign Source Income, Reed D. Rubinstein

Michigan Journal of International Law

Part I of this note will examine the structure of the FSC, and analyze its potential benefits in light of the Domestic International Sales Corporation (DISC) tax incentive. Part II discusses the use of the unitary tax as a disincentive to direct foreign investment by U.S. corporations. Finally, Part III outlines the new export policy based upon a combination of the FSC export incentive and state unitary taxation of foreign-source income. If implemented, this policy would increase export production and discourage direct foreign investment, thereby making a substantial contribution to U.S. economic well-being.