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Articles 1 - 30 of 89
Full-Text Articles in Law
Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault
Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault
Hugh J. Ault
No abstract provided.
Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault
Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault
Hugh J. Ault
No abstract provided.
Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Hugh J. Ault
In this Article, Professor Ault begins with an examination of the evolution of treaty principles for the allocation of and restrictions on international taxing jurisdiction. He then focuses on how economically based principles dealing with the taxation of international income affect treaty policy and presents the basic structural provisions involving the taxation of foreign income and foreign investors that emerge from domestically enacted or proposed integration systems. The technical aspects of the actual treaty practices that have been implemented with respect to integration systems are then related to the theoretical discussion. Professor Ault concludes with an examination of the implications …
Panelist, Oecd Conference On Intangibles, Hugh Ault
Panelist, Oecd Conference On Intangibles, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault
Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault
Hugh J. Ault
No abstract provided.
Transfer Pricing, Hugh Ault
Transfer Pricing, Hugh Ault
Hugh J. Ault
Chaired meeting of 45 governmental and academic specialist
Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold
Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold
Hugh J. Ault
The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime …
Panelist, The International Network For Tax Research And The American Journal Of Comparative, Conference On "Comparative Tax Law: Theory And Practice, Hugh Ault
Hugh J. Ault
No abstract provided.
Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault
Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault
Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault
Hugh J. Ault
No abstract provided.
2008 Oecd Model: The New Arbitration Provision, Hugh Ault
2008 Oecd Model: The New Arbitration Provision, Hugh Ault
Hugh J. Ault
New Art. 25(5), added to Art. 25 (Mutual agreement procedure) of the OECD Model as part of the 2008 Update, provides for the mandatory arbitration of unresolved issues arising in the course of a mutual agreement procedure. This article first examines the various factors that led to the adoption of Art. 25(5) and the stages of its development by the OECD. The article then discusses some technical aspects of the new arbitration provision, including the Sample Mutual Agreement setting out some procedural rules, which is attached as an Annex to Art. 25.
Session Chair, Oecd Advisory Group For Co-Operation With Non-Oecd Countries, Hugh Ault
Session Chair, Oecd Advisory Group For Co-Operation With Non-Oecd Countries, Hugh Ault
Hugh J. Ault
No abstract provided.
Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault
Panelist, Frankfurt International Arbitration Center: Tax Meets Arbitration, Hugh Ault
Hugh J. Ault
No abstract provided.
Reflections On The Role Of The Oecd In Developing International Tax Norms, Hugh Ault
Reflections On The Role Of The Oecd In Developing International Tax Norms, Hugh Ault
Hugh J. Ault
On September 8–9, 2008, the Organisation for Economic Cooperation and Development (“OECD”) held a Special Conference commemorating the 50th Anniversary of the OECD Model Tax Convention (“Model Convention” or “Model”). The Conference was attended by over 650 participants from the private sector and the government, representing over 100 countries. Both the level of participation and the geographical diversity represented at the conference would seem concrete evidence of the perceived importance of the role of the OECD in developing international tax norms. In his remarks opening the conference, the OECD Secretary General noted that the success of the OECD Model was …
Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda
Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda
Hugh J. Ault
In a practice article, Mitsuhiro Honda and Hugh J. Ault comment on a Tokyo High Court ruling that held that Japan's controlled foreign corporation rules are consistent with article 7(1) of the Japan-Singapore tax treaty.
Current Developments In Procedures For The Resolution Of International Tax Disputes, Hugh Ault
Current Developments In Procedures For The Resolution Of International Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault
Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault
Hugh J. Ault
No abstract provided.
Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault
Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault
Hugh J. Ault
No abstract provided.
Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault
Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault
Hugh J. Ault
No abstract provided.
Introduction To United States International Taxation, Hugh Ault, James Repetti, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, James Repetti, Paul Mcdaniel
Hugh J. Ault
The 2005 edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on ten specific aspects of the subject matter: -general aspects of the corporation income tax, the individual income tax, the …
Improving The Resolution Of International Tax Disputes, Hugh Ault
Improving The Resolution Of International Tax Disputes, Hugh Ault
Hugh J. Ault
The dramatic increase in international trade and investments and related phenomena under the general heading of Globalization have multiplied the situations in which international tax disputes can arise, both between taxpayers and governments but also, and in some ways, more importantly, between governments themselves. These disputes may involve transfer pricing issues, differing income characterization rules, disagreement about the existence of a permanent establishment, or more generally, diverging views on the appropriate exercise of potential taxing rights by the source country jurisdiction and the corresponding obligation of the residence country to provide double tax relief. In the current circumstances, it seems …
Review Of Foundations Of International Income Taxation, By Michael Graetz, Hugh Ault
Review Of Foundations Of International Income Taxation, By Michael Graetz, Hugh Ault
Hugh J. Ault
No abstract provided.
U.S. Exemption/Territorial System Vs. Credit-Based System, Hugh Ault
U.S. Exemption/Territorial System Vs. Credit-Based System, Hugh Ault
Hugh J. Ault
No abstract provided.
Taxation Of Income From Mobil Capital: Some Recent International Developments, Hugh Ault
Taxation Of Income From Mobil Capital: Some Recent International Developments, Hugh Ault
Hugh J. Ault
No abstract provided.
U.S. Corporate Taxation Reform From An International Perspective, Hugh Ault
U.S. Corporate Taxation Reform From An International Perspective, Hugh Ault
Hugh J. Ault
No abstract provided.
Arbitration In International Tax Matters: Some Structural Issues, Hugh Ault
Arbitration In International Tax Matters: Some Structural Issues, Hugh Ault
Hugh J. Ault
No abstract provided.
The Importance Of International Cooperation In Forging Tax Policy, Hugh J. Ault
The Importance Of International Cooperation In Forging Tax Policy, Hugh J. Ault
Hugh J. Ault
No abstract provided.
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Hugh J. Ault
No abstract provided.
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Hugh J. Ault
No abstract provided.
Tax Simplification From A Comparative Point Of View, Hugh Ault
Tax Simplification From A Comparative Point Of View, Hugh Ault
Hugh J. Ault
No abstract provided.