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Articles 1 - 12 of 12

Full-Text Articles in Law

For Realization: Income Taxation, Sectoral Accretionism, And The Virtue Of Attainable Virtues, Edward A. Zelinsky Dec 1997

For Realization: Income Taxation, Sectoral Accretionism, And The Virtue Of Attainable Virtues, Edward A. Zelinsky

Articles

No abstract provided.


The Hazards Of Tinkering With The Common Law Of Future Interests: The California Experience, Laura E. Cunningham Apr 1997

The Hazards Of Tinkering With The Common Law Of Future Interests: The California Experience, Laura E. Cunningham

Articles

No abstract provided.


The United States' Response To Tax Havens: The Foreign Base Company Services Income Of Controlled Foreign Corporations, Eric T. Laity Jan 1997

The United States' Response To Tax Havens: The Foreign Base Company Services Income Of Controlled Foreign Corporations, Eric T. Laity

Northwestern Journal of International Law & Business

This article is a detailed study of the taxation by the United States of foreign base company services income. Foreign base company services in- come is defined generally as the income derived by a controlled foreign corporation from the performance of services for a related person.2 Con- trolled foreign corporations, in turn, generally are the foreign subsidiaries of U.S. parent corporations.3 A controlled foreign corporation's foreign base company services income is taxed to its U.S. parent corporation, subject to various exclusions and qualifications. This article defines the class of sus- pect relationships between the controlled foreign corporation and its related …


Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt Jan 1997

Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt

LLM Theses and Essays

This thesis is going to describe the different ways the United States and Germany deal with the problem of double taxation in the legal context of corporate distributions to its shareholders in the form of dividends. Tax law is particularly one of the areas of laws that are subject to frequent and often substantial changes. This is true for the German as well as for the U.S. tax laws. Since some of the issues being discussed in the United States today in connection with the corporate tax law are similar if not identical to the issues discussed in Germany before …


Beyond Marking: Country Of Origin Rules And The Decision In Cpc International, 31 J. Marshall L. Rev. 179 (1997), Donna L. Bade Jan 1997

Beyond Marking: Country Of Origin Rules And The Decision In Cpc International, 31 J. Marshall L. Rev. 179 (1997), Donna L. Bade

UIC Law Review

No abstract provided.


Dumping And Anti-Dumping In International Trade Origins, Legal Nature, And Evolution Developments In Brazil And In The United States, Luiz Claudio Duarte Jan 1997

Dumping And Anti-Dumping In International Trade Origins, Legal Nature, And Evolution Developments In Brazil And In The United States, Luiz Claudio Duarte

LLM Theses and Essays

Dumping is when an exporting country sells their goods in the foreign market for less than the price of the goods in their own domestic market. Dumping has a negative connotation because it threatens domestic industries in the importing country. In response to harmful dumping situations, mechanisms of defense have been developed to protect nations from unfair trade practices. The General Agreement on Tariffs and Trade (GATT) recognizes in Article VI anti-dumping tariffs as a legitimate defense to protect domestic industries from foreign predatory pricing practices. This paper focuses on anti-dumping developments in international trade since the beginning of the …


The Limitation On Benefit Clause Of The U.S.-German Tax Treaty And Its Compatibility With European Union Law, Dietmar Anders Jan 1997

The Limitation On Benefit Clause Of The U.S.-German Tax Treaty And Its Compatibility With European Union Law, Dietmar Anders

Northwestern Journal of International Law & Business

This comment details why the limitation on benefits clause of the U.S.- German Treaty is contrary to European Union law.5 Part I describes the discriminatory situation which German companies may face and illustrates how tax treaty abuse could occur and how to prevent it. Part I also contains an introduction to the U.S.-German Treaty and provides an example of the conflict between U.S. tax treaties and European Union law. Part II analyzes in detail the Treaty's discriminatory features with respect to European Union aw and discusses potential justifications for this discrimination based on the case law of the European Court …


International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah Jan 1997

International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah

Articles

This article submits proposals for taxing the digital economy on the basis of the benefits and single tax principles.


Tax Court Ends The ‘Cascading Royalty’ Problem, Alan Appel Jan 1997

Tax Court Ends The ‘Cascading Royalty’ Problem, Alan Appel

Articles & Chapters

No abstract provided.


Valuation Of Closely Held Business Interests, Edwin T. Hood, John J. Mylan, Timothy P. O'Sullivan Jan 1997

Valuation Of Closely Held Business Interests, Edwin T. Hood, John J. Mylan, Timothy P. O'Sullivan

Faculty Works

No abstract provided.


Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons Dec 1996

Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons

Hugh J. Ault

Supplemented by 1998 Supplement: Federal Income Taxation of Partnerships and S Corporations. 2nd ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 1998; 1997 Supplement to Federal Income Taxation of Partnerships and S Corporations, 2nd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.


Comparative Income Taxation : A Structural Analysis, Hugh Ault Dec 1996

Comparative Income Taxation : A Structural Analysis, Hugh Ault

Hugh J. Ault

No abstract provided.