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Articles 1 - 30 of 101
Full-Text Articles in Law
Tax Competition And Tax Cooperation: A Survey And Reassessment, Hugh J. Ault
Tax Competition And Tax Cooperation: A Survey And Reassessment, Hugh J. Ault
Hugh J. Ault
No abstract provided.
Base Erosion And Profit Shifting: A Roadmap For Reform, Hugh Ault, Wolfgang Schoen, Stephen Shay
Base Erosion And Profit Shifting: A Roadmap For Reform, Hugh Ault, Wolfgang Schoen, Stephen Shay
Hugh J. Ault
In this Editorial, the authors explain the context of this special issue of the Bulletin for International Taxation. The fundamental premise of the BEPS project is that a coordination of national responses to BEPS can both eliminate double non-taxation and protect against material unrelieved double taxation. The articles in this issue further a dialogue among tax policymakers, taxpayers, advisors and academics that is critical to achieve this objective.
Invited Participant, United Nations Committee Of Experts On International Tax Matters, Hugh Ault
Invited Participant, United Nations Committee Of Experts On International Tax Matters, Hugh Ault
Hugh J. Ault
No abstract provided.
International Tax Developments And Family Businesses, Hugh Ault
International Tax Developments And Family Businesses, Hugh Ault
Hugh J. Ault
No abstract provided.
Dispute Resolution: The Mutual Agreement Procedure, Hugh Ault
Dispute Resolution: The Mutual Agreement Procedure, Hugh Ault
Hugh J. Ault
No abstract provided.
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Hugh J. Ault
This article is the revised text of a lecture held on May 2, 2013, at the Max Planck Institute for Tax Law and Public Finance. It focuses on the OECD's work on the definition of Permanent Establishment, the transfer pricing treatment of Intangibles and the recently announced project on base erosion and profit shifting ("BEPS"). After describing these positive law developments, Ault relates to more basic questions of how principles of international tax law, and particular the normative claims to taxing rights, are established.
Panelist, United Nations International Tax Compact, Technical Meeting On Administration And Negotiation Of Tax Treaties, Hugh Ault
Hugh J. Ault
No abstract provided.
Chair, United Nations, Special Meeting Of Ecosoc On International Cooperation In Tax Matters, Hugh Ault
Chair, United Nations, Special Meeting Of Ecosoc On International Cooperation In Tax Matters, Hugh Ault
Hugh J. Ault
No abstract provided.
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Some Reflections On The Oecd And The Sources Of International Tax Principles, Hugh Ault
Hugh J. Ault
No abstract provided.
The Oecd And Its Beps Project: Where Are We And Where Are We Going?, Hugh Ault
The Oecd And Its Beps Project: Where Are We And Where Are We Going?, Hugh Ault
Hugh J. Ault
No abstract provided.
The Recent Oecd Developments And The European Tax Integration Process, Hugh Ault
The Recent Oecd Developments And The European Tax Integration Process, Hugh Ault
Hugh J. Ault
No abstract provided.
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.
Oecd Project On Harmful Tax Practices, Hugh J. Ault
Oecd Project On Harmful Tax Practices, Hugh J. Ault
Hugh J. Ault
Materials presented in conjunction with a keynote speech delivered on May 15, 2003 at a congress on Tax Competition, organized by the European Tax College and held at Tilburg University, the Netherlands.
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 …
Taxation And Non-Discrimination: A Reconsideration, Hugh J. Ault, Jacques Sasseville
Taxation And Non-Discrimination: A Reconsideration, Hugh J. Ault, Jacques Sasseville
Hugh J. Ault
No abstract provided.
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
Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault
Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
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.