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Reply To Becker And Fuest, James R. Hines Jr.
Reply To Becker And Fuest, James R. Hines Jr.
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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, …
Comparative Tax Law: Theory And Practice, Reuven S. Avi-Yonah, Guy Inbar, Omri Marian, Linneu Mello
Comparative Tax Law: Theory And Practice, Reuven S. Avi-Yonah, Guy Inbar, Omri Marian, Linneu Mello
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On 3 October 2009, a Conference on Comparative Tax Law in Theory and Practice took place at the University of Michigan Law School. It was organized by Reuven Avi-Yonah (Professor, University of Michigan Law School) and Mathias Reimann (Editor, American Journal of Comparative Law and Professor, University of Michigan Law School), and was attended by Hugh Ault (Professor of Law, Boston College Law School), Victor Thuronyi (Senior Counsel, International Monetary Fund), Brian Arnold (Professor Emeritus, University of Western Ontario), William Barker (Professor, The Dickinson School of Law, Penn State), Michael Livingston (Professor, Rutgers School of Law-Camden), Carlo Garbarino (Professor of …