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Full-Text Articles in Law
Racketeering, Rico And The Revenue Rule In Attorney General Of Canada V. R.J. Reynolds: Civil Rico Claims For Foreign Tax Law Violations, Elizabeth J. Farnam
Racketeering, Rico And The Revenue Rule In Attorney General Of Canada V. R.J. Reynolds: Civil Rico Claims For Foreign Tax Law Violations, Elizabeth J. Farnam
Washington Law Review
When Congress passed the Racketeer Influenced Corrupt Organizations Act (RICO), it created a civil cause of action for any entity, including a foreign government, to recover for injury caused by a defendant's pattern of racketeering activity. However, Congress did not expressly indicate how the revenue rule, a conflict of laws doctrine that allows a court to decline to enforce a foreign government's tax claim or judgment, would relate to civil RICO claims. In Attorney General of Canada v. R.J. Reynolds Tobacco Holdings, Inc., the United States Court of Appeals for the Second Circuit held that the revenue rule barred …
Implications Of Singapore's Income And Consumption Tax Policies On International E-Commerce Transactions Of Digitized Products, Neal Harold Luna
Implications Of Singapore's Income And Consumption Tax Policies On International E-Commerce Transactions Of Digitized Products, Neal Harold Luna
Washington International Law Journal
The Internet's current architecture allows international e-commerce transactions of digitized goods to go untaxed by the country in which the income was earned or the product consumed. The inability of these countries to tax such transactions will erode their tax bases as e-commerce in digitized products grows relative to other commercial forms. To forestall the erosion of its tax base, Singapore's revenue authority boldly extends its existing consumption and income tax policies to e-commerce. Singapore's proposed e-commerce tax regime is a model from which other countries—both those with similar tax regimes, such as the E.U. member economies, and those that …
Liability To Tax And Transfer Pricing In The People's Republic Of China: A Comparative Analysis, William A. Thomson
Liability To Tax And Transfer Pricing In The People's Republic Of China: A Comparative Analysis, William A. Thomson
Washington International Law Journal
This Article explains how easy it is to become liable to People's Republic of China ("PRC") income tax, and examines the PRC transfer pricing rules. It compares China's tax regime to that of the United States and Japan, focusing both on China's domestic tax law and its treaty obligations. The purpose of this comparison is to illuminate the inter-related tax rules between China and the United States, and China and Japan. The Article also explains how China has modernized its tax system in line with its economic liberalization, and points out areas of uncertainty regarding China's rules on tax liability …
An Agenda For Revising The Taxation Of Philanthropy In Japan, Koji Ishimura
An Agenda For Revising The Taxation Of Philanthropy In Japan, Koji Ishimura
Washington International Law Journal
As the size and scope of Japan's philanthropic activities have grown, so has the need to re-examine Japan's tax policies with regards to charitable giving and volunteerism. In particular, there is a need to review the classification of tax-exempt entities under the Corporate Tax Law to ensure that only bona fide non-profit activities are tax-exempt. Japan should also explore new tax incentives to encourage volunteerism, such as allowing deductions for out-of-pocket expenses incident to charity work, carryovers, and a liberalization of Japan's current system for specific itemized deductions. Finally, Japan's tax policies should be used to encourage more cross-border philanthropy …