Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Business-purpose doctrine (1)
- Capital expenditures (1)
- Commissioner v. Tufts (1)
- Corporate income taxation (1)
- Customary international law (1)
-
- EC (1)
- European Community treaty (1)
- Formulary Apportionment Method (1)
- G.M. Leasing Corp. v. United States (1)
- GATT (1)
- General Agreement on Tariffs and Trade (1)
- International taxation (1)
- Justice Harry Blackmun (1)
- Knetsch v. United States (1)
- Multinational corporations (1)
- NAFTA (1)
- Non-tax treaties (1)
- North American Free Trade Agreement (1)
- Progressive rate structure (1)
- Residence-based taxation (1)
- Separate Accounting Method (1)
- Source-based income taxation (1)
- State taxation (1)
- Tax expenditure budgets (1)
- Tax jurisprudence (1)
- Tax policy (1)
- Tax teaties (1)
- Transfer price manipulation (1)
- United States v. Carlton (1)
- WTO (1)
Articles 1 - 6 of 6
Full-Text Articles in Law
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Cornell Law Faculty Publications
This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Cornell Law Faculty Publications
During his tenure on the Supreme Court, Justice Blackmun was widely regarded as the Court's authority on tax matters. Justice Blackmun viewed tax law not merely as a technical specialty, but as a microcosm of the legal system. His numerous tax opinions involve a wide range of issues of constitutional law, criminal law, administrative procedure, court procedure, and statutory interpretation. This Article begins by discussing two of Justice Blackmun's tax opinions involving constitutional issues. Justice Blackmun refused to create special constitutional rules for tax cases. Instead, he applied generally applicable principles, but with great sensitivity to how those principles would …
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Cornell Law Faculty Publications
No abstract provided.
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green
Cornell Law Faculty Publications
Tax Expenditure Budgets: A Critical View, Jeffrey S. Lehman, Douglas A. Kahn
Tax Expenditure Budgets: A Critical View, Jeffrey S. Lehman, Douglas A. Kahn
Cornell Law Faculty Publications
No abstract provided.
A Critique Of The Business-Purpose Doctrine, Robert S. Summers
A Critique Of The Business-Purpose Doctrine, Robert S. Summers
Cornell Law Faculty Publications
The aims of this article are: (1) to define the nature and significance of the business-purpose doctrine as applied in the field of Federal income taxation; (2) to summarize several considerations that support abandonment of the doctrine; and (3) to consider whether a substitute doctrine is needed. Several recent cases indicate that the influence of the business-purpose doctrine is declining, and in the recent case of Knetsch v. United States the Supreme Court appears to have substituted an alternative doctrine. The dual thesis of the present article is that the business-purpose doctrine ought to be abandoned and that there is …