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Full-Text Articles in Law
Direct Taxation-Whither In The Single Market Of 1992?, Philip Bentley
Direct Taxation-Whither In The Single Market Of 1992?, Philip Bentley
BYU Law Review
No abstract provided.
A Capital Tax System To Preserve America's Heritage, Valerie M. Fogleman
A Capital Tax System To Preserve America's Heritage, Valerie M. Fogleman
Vanderbilt Journal of Transnational Law
This Article looks to the British national heritage capital tax system as a model to propose provisions in the United States Internal Revenue Code to aid in preserving the United States cultural and natural heritage. After an overview of the capital tax systems in Britain and the United States, Ms. Fogleman examines features of the British tax system that promote preservation of the national heritage. The British system conditionally exempts the owners of national heritage assets from estate or gift tax liability on the transfer of those assets in exchange for permitting public access to and maintaining the assets; allows …
Foreign Taxation: The Section 367(E) Regulations -- No Place To Hide, Walter D. Schwidetzky
Foreign Taxation: The Section 367(E) Regulations -- No Place To Hide, Walter D. Schwidetzky
Northwestern Journal of International Law & Business
Foreign taxpayers have long been a thorn in the side of Congress. Not only is the proper incidence of tax a far greater issue than in the domestic context, so is whether that tax will ever be collected. The average foreign taxpayer, with little the IRS can readily attach, is not overly concerned with whether the United States tax bill has been paid. Consequently, the Internal Revenue Code of 1986 (the Code) has a number of provisions designed to overcome the reluctance of foreign taxpayers to pay United States tax.