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Full-Text Articles in Law
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.
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.
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.
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.
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.
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.
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Le Travail Accompli Par L'Ocde Et Son Esprit, Hugh Ault
Hugh J. Ault
No abstract provided.
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault
Hugh J. Ault
An updated version appears inIntertax 4 (April 1994): 144-148.
The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault
The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault
Hugh J. Ault
No abstract provided.
Commentary [On `The Foreign Tax Credit And Its Critics,' By Charles I. Kingson, Hugh Ault
Commentary [On `The Foreign Tax Credit And Its Critics,' By Charles I. Kingson, Hugh Ault
Hugh J. Ault
No abstract provided.
Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford
Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford
Hugh J. Ault
No abstract provided.
Foreign Tax Provisions Of H.R. 3838, Hugh Ault, Stanford Ross, Gerard Brannon
Foreign Tax Provisions Of H.R. 3838, Hugh Ault, Stanford Ross, Gerard Brannon
Hugh J. Ault
No abstract provided.
The Unitary Tax Controversy: Federalism, Treaties And International Tax Relationships, Hugh Ault
The Unitary Tax Controversy: Federalism, Treaties And International Tax Relationships, Hugh Ault
Hugh J. Ault
No abstract provided.
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Hugh J. Ault
Introduction à la Fiscalité Internationale Américaine, translated by Arthur Young and Company, 1982.
Social Security Totalization Agreement With The Federal Republic Of Germany, Hugh Ault
Social Security Totalization Agreement With The Federal Republic Of Germany, Hugh Ault
Hugh J. Ault
No abstract provided.
The Effect Of Losses In One Country On The Income Tax Treatment In Another Country Of An Enterprise Or Of Associated Companies Engaged In International Activities, Hugh Ault, Donald Gerwig, Michael Henning
The Effect Of Losses In One Country On The Income Tax Treatment In Another Country Of An Enterprise Or Of Associated Companies Engaged In International Activities, Hugh Ault, Donald Gerwig, Michael Henning
Hugh J. Ault
No abstract provided.
Present Legislation And A Rational Structure For The Operation Of The Credit Mechanism, Hugh Ault
Present Legislation And A Rational Structure For The Operation Of The Credit Mechanism, Hugh Ault
Hugh J. Ault
No abstract provided.
Lehre Und Forschung Im Steurrecht In Den Usa, Hugh Ault
Lehre Und Forschung Im Steurrecht In Den Usa, Hugh Ault
Hugh J. Ault
No abstract provided.