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Full-Text Articles in Law
Taxing Emotional Distress Recoveries: Does Murphy Show The Way?, Kaushal P. Mahaseth
Taxing Emotional Distress Recoveries: Does Murphy Show The Way?, Kaushal P. Mahaseth
LLM Theses and Essays
The taxability of recoveries of damages on account of emotional distress remains a complicated issue under the American federal income tax law. Recent developments due to a controversial decision by the D.C. Circuit Court of Appeals have further added fuel to this debate. Even if one were to argue the justifications of exempting such recoveries from income taxation, courts do not appear to be the very appropriate kind of forum. Congress can, and in fact does tax such recoveries and the constitutional basis of such power can hardly be doubted. As a result, appropriate changes in the statute only can …
The Challenges Of Tax Collection In Developing Economies (With Special Reference To India), Pramod K. Rai
The Challenges Of Tax Collection In Developing Economies (With Special Reference To India), Pramod K. Rai
LLM Theses and Essays
This paper gives an overview of the Indian tax system and discusses the challenges in tax collection faced by developing economies using India as a model. The paper discusses the ways and means to reduce the black economy and to improve tax compliance for better collection of revenue. The paper further proposes the establishment of a dispute resolution system in developing economies similar to that of the United States for speedy and fair settlement of taxation disputes.
Current Problems Of International Taxation Of Electronic Commerce, Nuran G. Kerimov
Current Problems Of International Taxation Of Electronic Commerce, Nuran G. Kerimov
LLM Theses and Essays
This thesis discusses the main problems that face tax authorities of many countries in the process of taxation of electronic commerce. It analyzes examples of problems posed by the growth of e-commerce in the context international direct and indirect taxation. Current international policy issues are the subject of discussion of the thesis. The thesis also analyzes some of the proposals regarding taxation of electronic commerce.
Evolution Of The Arm's Length Standard In The Us Transfer Pricing Legislation And Russian Arm's Length Perspective, Andrei A. Shutov
Evolution Of The Arm's Length Standard In The Us Transfer Pricing Legislation And Russian Arm's Length Perspective, Andrei A. Shutov
LLM Theses and Essays
This thesis analyzes the evolution of the arm's length standard (ALS) as the key element of the transfer pricing control system in the US. This thesis also addresses some issues on creation of transfer pricing legislation in the Russian Federation and focuses on three sets of problems. First, it provides the general outline of the legislative history of the ALS as well as the history of the ALS' application in the US, including an overview of landmark cases, which revealed some conceptual problems with respect to the ALS. Secondly, the thesis addresses core problems associated with the ALS, such as …
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
LLM Theses and Essays
The instant thesis is organized in three main parts. The first contains an overview of U.S. law including constitutional issues of the topic focusing on the separation of tax powers between federal and state authorities with special attention to the basis and extent to which a State is entitled to impose levies on business organizations; a brief analysis of federal legislation allowing the pass-through regime; and summary concerning LLC legislation in the States. The second analyzes the application of the main, basic principles of international taxation (such as residence, source rules, application of international treaties, and connected with it the …
Taxing The Reticulum Taxation And Tariff Issues In Electronic Commerce, Neil Lovett Wilkinson
Taxing The Reticulum Taxation And Tariff Issues In Electronic Commerce, Neil Lovett Wilkinson
LLM Theses and Essays
This thesis will explore, first within a historical context, and second, in a contemporary model, the impact and effect of electronic commerce in both a general and Electronic magazines. The thesis will explore governmental and legal responses, from a taxation and tariff point of view to the challenges posed by commercial transactions initiated and completed via the Internet and the World Wide Web. The broad question is therefore presented: How should governments, primarily American state and local governments, but also governments worldwide, respond to changes in technology that have a direct effect on the way business is conducted within their …