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Articles 1 - 30 of 37
Full-Text Articles in Law
Money Grab: How The G20/Oecd Inclusive Framework For Taxation Could Unnecessarily Disrupt Corporate Incentives And Misallocate Taxing Rights, William T. Anderson
Money Grab: How The G20/Oecd Inclusive Framework For Taxation Could Unnecessarily Disrupt Corporate Incentives And Misallocate Taxing Rights, William T. Anderson
Vanderbilt Journal of Transnational Law
The Organisation of Economic Co-operation and Development (OECD) is proposing a dramatic shift to international corporate taxation that both sets a floor for corporate tax rates across the globe and transforms how countries obtain taxing rights over large multinational corporations. This Note focuses on the proposed framework for re-allocating taxing rights over corporations away from the traditional requirement of a physical presence in a country to mere revenues in a country. This Note identifies problems with the proposal as it relates to artificially altering corporate incentives and structures, as well as the proposal's incompatibility with theories of taxation- including Adam …
If You Can't Beat Them, Join Them: The U.S. Solution To The Issue Of Corporate Inversions, Scott Deangelis
If You Can't Beat Them, Join Them: The U.S. Solution To The Issue Of Corporate Inversions, Scott Deangelis
Vanderbilt Journal of Transnational Law
There is an old proverb, "If you can't beat them, join them, "that suggests that those who cannot win against some group should stop fighting and instead band together with them. It seems clear that when it comes to corporate inversions, the United States cannot win. Instead, countries overseas have taken advantage of tax break schemes to lure multinational companies away from the United States. This Note suggests that to prevent further foreign inversions, the United States should join these foreign countries in two ways. First, the United States should put its support behind the OECD's plan of a multilateral …
Spontaneous Tax Coordination: On Adopting A Comparative Approach To Reforming The U.S. International Tax Regime, Anthony C. Infanti
Spontaneous Tax Coordination: On Adopting A Comparative Approach To Reforming The U.S. International Tax Regime, Anthony C. Infanti
Vanderbilt Journal of Transnational Law
The excessive complexity of the U.S. international tax regime is well documented. Although many commentators have cited the need for simplification, their proposals often maximize other policy goals at the expense of simplicity. Even reform proposals aimed principally at clarifying the tax code are ordinarily focused on the "internal" complexity of the code, seeking improvements only for U.S. taxpayers struggling with a single complex provision of the code or the baffling interaction, of two U.S. rules. This Article focuses on the interaction between U.S. tax law and the rules of other nations, and is intended to illustrate the benefits that …
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey, Elyse G. Kirschner
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey, Elyse G. Kirschner
Vanderbilt Journal of Transnational Law
The Small Business Job Protection Act of 1996 (the 1996 Act) was intended to deal a heavy blow to the appeal of foreign trusts to U.S. persons. The results were mixed. On the one hand, the 1996 Act imposes an array of reporting requirements, imposes harsh penalties on failures to comply with these requirements, increases the interest charge imposed on taxes paid on distributions of accumulated income from foreign trusts, treats loans of cash from foreign trusts as distributions, and expands the kinds of gifts that can be treated as indirect transfers from foreign trusts. On the other hand, curiously, …
Respect For "Form" As "Substance" In U.S. Taxation Of International Trusts, Donald D. Kozusko, Stephen K. Vetter
Respect For "Form" As "Substance" In U.S. Taxation Of International Trusts, Donald D. Kozusko, Stephen K. Vetter
Vanderbilt Journal of Transnational Law
...we might decide that the attribution rule should not be applied so broadly, or so automatically. But how would such a system be devised by regulation? The attribution rule could be applied to trusts in which the discretion of the trustee is very limited and the beneficial interests so clearly ascertainable that the trust is, for all practicable purposes, transparent. That is, however, only a small universe of cases. This leads to the further conclusion that the attribution rule has to be applied based on a facts and circumstances determination of the beneficial interest in each case. Yet that seems …
Emerging Leader Of The Tax Avant-Garde, Andrzej J. Burba
Emerging Leader Of The Tax Avant-Garde, Andrzej J. Burba
Vanderbilt Journal of Transnational Law
In 1998, Poland's Minister of Finance Leszek Balcerowicz unveiled a plan to restructure the tax system. His fiat tax proposal promises numerous benefits to individual and corporate taxpayers with significant reduction in tax rates for both groups. The new plan offers to further strengthen Poland's growing economy--a consequence that is especially significant in light of the country's aspiration to join the European Union. It provides a remedy for virtually every ailment plaguing the current tax system and, most importantly, the reform offers to finance itself This Note argues that the plan should be adopted immediately for the following reasons: (1) …
United States Tax Rules For Nonresident Authors, Artists, Musicians, And Other Creative Professionals, Don R. Spellmann
United States Tax Rules For Nonresident Authors, Artists, Musicians, And Other Creative Professionals, Don R. Spellmann
Vanderbilt Journal of Transnational Law
Although the United States rules for taxation of non-resident creative professionals may seem straight forward, the Internal Revenue Code contains significant traps for the unwary nonresident. However, it also offers significant opportunities for nonresidents to protect themselves from United States taxation. Discovering these traps and loopholes requires close attention to the Code and to income tax treaties which further complicate the system. This Note examines the Code's rules on taxation of nonresidents and discusses the effect that tax treaties have on those rules. The Note, intended to be a practical guide for nonresident authors, artists, musicians, and other creative professionals, …
Common Misconceptions: The Function And Framework Of "Trade Or Business Within The United States", Nancy H. Kaufman
Common Misconceptions: The Function And Framework Of "Trade Or Business Within The United States", Nancy H. Kaufman
Vanderbilt Journal of Transnational Law
In this Article, Professor Kaufman examines the administrative and jurisdictional functions of the Internal Revenue Code's term "trade or business within the United States" in the taxation of foreign persons' income and the existing framework established for the term's interpretation. The author contends that the courts, by relying on two common misconceptions of the term, have made the term's application unpredictable. The author further believes that defining the term according to its functions would serve United States tax policy and economic interests. This definition would focus primarily on facts indicating an ongoing commitment to participation the United States economy. The …
Case Digest, Law Review Staff
Case Digest, Law Review Staff
Vanderbilt Journal of Transnational Law
United States Tax Principles Govern Determination of Accumulated Profits Under Foreign Tax Credit Section of Internal Revenue Code, United States v. Goodyear Tire & Rubber Co. 110 S. Ct. 1172 (1990).
Tax Injunction Act Bars Foreign Parent of Subsidiary Doing Business in California from Raising Foreign Commerce Objections to Tax Board's Formula Franchise Tax Board of California v. Alcan Aluminum Ltd. 110 S. Ct. 661 (1990).
Correspondence Bank Account with United States Trust Company Held Insufficient Contact with United States to Establish Subject Matter Jurisdiction under the FSIA--International Housing Ltd. v. Rafidain Bank Iraq, 893 F.2d 8(2d Cir. 1989).
Successful …
Back To The Future: A Time For Rethinking The Test For Resident Alien Status Under The Income Tax Laws, David Williams, Ii
Back To The Future: A Time For Rethinking The Test For Resident Alien Status Under The Income Tax Laws, David Williams, Ii
Vanderbilt Journal of Transnational Law
If the sole object of our tax law is certainty, then the quest for a bright-line, mechanical test would appear to be justified. Fairness, however, is an equally important objective. If fairness is sacrificed in our rush to formulate a bright-line test, then the law is not fully successful. The trade-off between certainty and fairness attains particular significance for non-United States citizens earning income in this country. Under United States tax laws, these individuals may be taxed as either resident aliens or nonresident aliens. This classification can be crucial because the resident alien is taxed on his worldwide income; the …
Case Digest, Law Review Staff
Case Digest, Law Review Staff
Vanderbilt Journal of Transnational Law
Neither Private Refugee Assistance Agency Nor its Members have Standing to Contest U.S. Interdiction of Foreign Vessels on High Seas Carrying Undocumented Aliens Haitian Refugee Center v. Gracey, No. 85-5258, slip op. (D.C. Cir. Jan. 9, 1987).
Separation of Citizen Children from Illegal Alien Parents Should be Considered when Determining Extreme Hardship Deportation Proceedings -Cerillo-Perez v. INS, 55 U.S.L.W.2457 (9th Cir. 1987).
California State Court's Exercise of Personal Jurisdiction over Japanese Manufacturer to Indemnify Taiwanese Company is Unreasonable and Unfair in Violation of Due Process. Asahi Metal Industry Co. v. Superior Court of California, 107 S. Ct.1026 (1987).
Nondiscriminatory Ad …
Case Digest, Law Review Staff
Case Digest, Law Review Staff
Vanderbilt Journal of Transnational Law
GOOD FAITH EXCEPTION TO THE EXCLUSIONARY RULE EXTENDS TO FOREIGN CRIMINAL INVESTIGATIONS WHERE UNITED STATES NARCOTICS AUTHORITIES REASONABLY RELIED ON FOREIGN LAW ENFORCEMENT OFFICERS' REPRESENTATIONS THAT SEARCH COMPLIED WITH THE FOREIGN COUNTRY'S LAW--United States v. Peter-son, 812 F.2d 486 (9th Cir. 1987).
ASSETS OF A WHOLLY-OWNED FOREIGN INSTRUMENTALITY ARE NOT SUBJECT TO ATTACHMENT TO SATISFY JUDGMENT AGAINST A FOREIGN STATE UNLESS PLAINTIFF OVERCOMES PRESUMPTION OF INDEPENDENT STATUS--Hercaire Int'l, Inc. v. Argentina, 821 F.2d 559(11th Cir. 1987).
UNITED STATES DISTRICT COURT HAS SUBJECT MATTER JURISDICTION OVER MEXICAN CONSULAR OFFICIALS FOR THEIR ALLEGED ATTEMPTS TO SUPPRESS CRITICAL DEMONSTRATIONS OUTSIDE MEXICAN CONSULATE IN …
Books Received, Law Review Staff
Books Received, Law Review Staff
Vanderbilt Journal of Transnational Law
Books Received
The Human Rights of Aliens in Contemporary International Law By Richard B. Lillich Dover, New Hampshire: Manchester University Press, 1985. Pp. xii, 126. $38.00
Banking on the Act of State By Carsten Thomas Ebenroth Universitdtsverlag Konstanz Gmbh: 1985. Pp. 101.DM66,80.
The Iran-United States Claims Tribunal, 1981-1983 Edited by Richard B. Lillich Charlottesville, Virginia: The University Press of Virginia, 1985. Pp. viii, 156. $25.00
Emerging Standards of International Trade and Investment Edited by Seymour J. Rubin and Gary Clyde Hufbauer Totowa, New Jersey: Rowman & Allanheld, 1984. Pp. ix,196
The World of International Tax Planning By Milton Grundy New …
United States Investment In Ireland, Eugene P. Fanning
United States Investment In Ireland, Eugene P. Fanning
Vanderbilt Journal of Transnational Law
This Article will examine in general the structure of the Irish Government relating to foreign investment, and describe the role of the government agencies that provide incentives for foreign direct investments. The Article will focus on the negotiation process between those government agencies and foreign investors, and examine the typical investment contract entered into by United States investors. The Article will also describe some important aspects of the typical forms of direct investment in Ireland: manufacturing, service industry, and joint venture investments. This Article will examine the concept of tax-advantaged lending in Ireland, Ireland's foreign exchange control regulations, and its …
Irish Tax Law And The Foreign Investor, Conor Crowley, Paul Mcgowan
Irish Tax Law And The Foreign Investor, Conor Crowley, Paul Mcgowan
Vanderbilt Journal of Transnational Law
For over twenty-five years, successive Irish Governments have actively sought and encouraged foreign investment in Ireland. With the exception of the insurance industry, Irish statutes grant foreigners the same rights as citizens of Ireland to establish whatever type of business they desire. A minimum native Irish interest in any business is required only for the issue or transfer of shares to, or the establishment of, a business branch operation by nonresidents. Although these transactions require Exchange Control approval, that approval is usually a formality for investments expected to bring an economic benefit to Ireland.
State Taxation Of Foreign Source Income Through Worldwide Combined Reporting, Thomas C. Pearson
State Taxation Of Foreign Source Income Through Worldwide Combined Reporting, Thomas C. Pearson
Vanderbilt Journal of Transnational Law
The primary alternative to worldwide combined reporting is the method used by the United States Government--the arm's length method of taxing foreign source income. Following the explanation of the arm's length method, this Note will outline briefly the due process and commerce clause limitations on a state's jurisdiction to tax and will describe the methods states have chosen to apportion the business income of a unitary business in order to comply with the commerce clause. The impact of worldwide combined reporting depends upon the apportionment formula adopted by the state and the state's definition of the terms "unitary business" and …
Books Received, Law Review Staff
Books Received, Law Review Staff
Vanderbilt Journal of Transnational Law
Casebook on Carriage by Sea.
By E.R. Hardy Ivamy
London: Lloyd's of London Press, 1982. Pp. xxxix, 203. £11.50.
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Casebook on Shipping Law
By E.R. Hardy Ivamy
London: Lloyd's of London Press, 1982. Pp. xxx, 205. £11.50.
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Regional Development Agencies in Europe
Edited by Douglas Yuill
Hampshire, England: Gower, 1982. Pp. vii, 449.$44.50.
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United States Trade Policy Legislation: A Canadian View
By Rodney de C. Grey
Montreal: The Institute for Research on Public Policy, 1982. Pp. xvii, 130. $7.95.
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Transfer of Technology: U.S. Multinationals and Eastern Europe
By Marilyn L. Liebrenz
New York: Praeger Publishers, 1982. …
United States Employment Taxation Of German Nationals Working In The United States, John L. Gornall, Jr., Kevin Conboy
United States Employment Taxation Of German Nationals Working In The United States, John L. Gornall, Jr., Kevin Conboy
Vanderbilt Journal of Transnational Law
This Article begins with a discussion of the general application of FICA, SECA, and FUTA to nonresident aliens. Knowledge of the ordinary United States employment taxation scheme is necessary for an understanding of how the totalization agreement works.
The second part of this Article explains how totalization agreements between the United States and certain foreign countries--including the Federal Republic of Germany--have altered the United States employment taxation of nonresident aliens. These agreements generally provide the following: (1) the foreign worker and employer may pay taxes and receive benefits from either the home country or the temporary host country, but in …
Legal Issues Relating To The Canadian National Energy Program, Jean-Paul Lacasse
Legal Issues Relating To The Canadian National Energy Program, Jean-Paul Lacasse
Vanderbilt Journal of Transnational Law
Since its unveiling on October 28, 1980, Canada's National Energy Program has been commented upon abundantly in government circles, newspaper articles, trade magazines, and financial industry seminars, drawing both oil industry and foreign reactions. It has received less notice in scholarly publications, however, perhaps because it is a complex and continuously changing program that did not become effective until legislation was enacted. The purpose of this Article is to sketch a broad picture of the National Energy Program (NEP) while focusing on its Canadianization aspects, the new oil and gas taxation situation, and the Program's various transnational law implications. As …
Case Digest, Law Review Staff
Case Digest, Law Review Staff
Vanderbilt Journal of Transnational Law
EMPLOYEE WHO SPENDS "SOME PORTION OF WORK TIME IN MARITIME ACTIVITIES" IS AN "EMPLOYEE" COVERED BY THE LONGSHOREMEN'S AND WORKERS' COMPENSATION ACT-Schwabenland v.Sanger Boats, 683 F.2d 309 (9th Cir. 1982)
UNITED STATES CARRIAGE OF GOODS BY SEA ACT EXEMPTS DEFENDANT FROM LIABILITY FOR SHIP DAMAGE INCURRED WHILE DISCHARGING CARGO--Seven Seas Transportation Ltd. v. Pacifico Union Marina Corp. [1982] 2 Lloyd's L.R. 465
IMMIGRATION AND NATURALIZATION SERVICE DISTRICT DIRECTOR IS ENTITLED TO BROAD DISCRETION IN WEIGHING CRITERIA FOR PAROLE DETERMINATION OF UNADMITTED ALIENS--Bertrand v. Sava,684 F.2d 204 (2d Cir. 1982)
THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT DOES NOT APPLY TO …
Case Digest, Law Review Staff
Case Digest, Law Review Staff
Vanderbilt Journal of Transnational Law
APPLICATION OF UNITED STATES LAW TO A FOREIGN SEAMAN'S SUIT DEPENDS UPON THE SUBSTANTIALITY OF THE FOREIGN DEFENDANT'S CONTACTS WITH THE UNITED STATES--Szumlicz v. Norwegian America Line, Inc., 698 F.2d 1192 (11th Cir. 1983).
RECOVERY PURSUANT TO THE FISHERMEN'S PROTECTIVE ACT FOR LOSSES RESULTING FROM SEIZURE OF VESSLS FISHING IN DISPUTED WATERS Is NOT LIMITED TO CITIZENS AND RESIDENT ALIENS OF THE UNITED STATES-CrUZ V. Zapata Ocean Resources, Inc., 695 F.2d 428 (9th Cir. 1982).
UNITED STATES SUPPORT OF CANADIAN SEARCH OF UNITED STATES VESSEL ON THE HIGH SEAS DID NOT VIOLATE DEFENDANT'S FOURTH AMENDMENT RIGHTS--United States v. Hensel, 699 …
Books Received, Journal Staff
Books Received, Journal Staff
Vanderbilt Journal of Transnational Law
Books Received
Utilization of Outer Space and International Law
Gijsbertha C.M. Reijnen.
Amsterdam and New York: Elsevier Scientific Publishing Company, 1981. Pp. 179, $69.75.
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International Estate Planning
William H. Newton, III.
Colorado Springs: Shepard's/McGraw-Hill Company, 1981. Pp. 614.
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International Tax Avoidance and Evasion, Colloquy of the Council of Europe, Strasbourg, 1980
Publication 31, Publications of the International Bureau of Fiscal Documentation Amsterdam: International Bureau of Fiscal Documentation, 1981. Pp.184, Dfl. 65.00.
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Fiscal Reform in Bolivia: Final Report on the Bolivian Mission on Tax Reform Richard A. Musgrave
Cambridge: Harvard Law School International Tax Program, 1981. Pp. 593, …
Book Reviews, Edward C. Brewer, Iii., W. Paul Gormley, Allaire U. Karzon.
Book Reviews, Edward C. Brewer, Iii., W. Paul Gormley, Allaire U. Karzon.
Vanderbilt Journal of Transnational Law
DIRECT INVESTMENT AND DEVELOPMENT IN THE U.S.: A GUIDE TO INCENTIVE PROGRAMS, LAWS AND RESTRICTIONS 1980-1981
Raymond Waldmann
Washington D.C.: Transnational Investments, Ltd.; London: Kluwer Publishing, 1980. Pp. viii, 443. $75.00, London £45 plus £1 surface mail.
Reviewed by Edward C. Brewer, III.
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NUCLEAR ENERGY AND NUCLEAR WEAPON PROLIFERATION
Frank Barnaby, Jozef Goldblat, Bhupendra Jasani, and Joseph Rotblat,eds. Published for the Stockholm International Peace Research Institute. London: Taylor & Francis, 1979. Pp. xxiv, 462.
Reviewed by W. Paul Gormley
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INTERNATIONAL ASPECTS OF U.S. INCOME TAXATION Vois. I and III
Elisabeth Owens Boston, Mass.: Harvard Law School, 1980. Pp.305. …
Domestic International Sales Corporations (Discs): How They Provide A Tax Incentive For Exports, Garrison R. Cox
Domestic International Sales Corporations (Discs): How They Provide A Tax Incentive For Exports, Garrison R. Cox
Vanderbilt Journal of Transnational Law
This Note examines the logical and empirical validity of the reasons for the passage of the DISC legislation. Basically, the DISC legislation was prompted by the negative trade balance in 1971, a novel phenomenon in post-World War II United States. Providing a tax break on producers' export income was viewed as a way of reducing trade deficits by stimulating exports. On its surface, using "tax expenditures" to reach this goal seems logical, or at least benign. But when one considers that the primary thrust of the legislation was to encourage small producers to enter the export market, the logic of …
Recent Decisions, Kevin P. Hishta, J. Clifton Cox, Shari D. Olenick, Stephen B. Hatcher, Ann M. Bell
Recent Decisions, Kevin P. Hishta, J. Clifton Cox, Shari D. Olenick, Stephen B. Hatcher, Ann M. Bell
Vanderbilt Journal of Transnational Law
ALIENS--Executive Suspension of Alien's Deportable Status Final as Congressional Veto Mechanism violates Constitutional Doctrine of Separation of Powers
Kevin P. Hishta
--------------------------- Sovereign Immunity--Iranian Immunity from Pre-Judgment Attachments Terminated under International Emergency Economic Powers Act
J. Clifton Cox
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Sovereign Immunity--Government Shipping Company of the People's Republic of China is an "Agency or Instrumentality" for the Purposes of the Foreign Sovereign Immunities Act of 1976
Shari D. Olenick
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State Corporate Income Tax--Foreign Source Dividends Included in State Taxation Base Under Unitary Business Enterprise Test
Stephen B. Hatcher
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Trade Regulation--Use of Registered Mail by Federal Trade Commission to Subpoena …
Books Received, Journal Staff
Books Received, Journal Staff
Vanderbilt Journal of Transnational Law
THE HOST STATE AND THE TRANSNATIONAL CORPORATION: AN ANALYSIS OF LEGAL RELATIONSHIPS
By Juha Kuusi
Farnborough, England: Saxon House, 1979. Pp. 177. $25.25 (Distributed by Renouf USA, Brookfield, Vermont.)
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THE INDIRECT CREDIT Vol. II
By Gerald Ball and Elizabeth A.Owens
Cambridge, Mass.: The International Tax Program, Harvard Law School, 1979. Pp. 406. $40.00.
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JURIDICA: ANUARIO DEL DEPARTAMENTO DEL DERECHO DE LA UNIVERSIDAD IBEROAMERICANA
Edited by Enrique Portilla Osio Mexico City: Universidad Iberoamericano. 1978. Pp. 595.
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LES SANCTIONS PRIVATES DE DROITS Ou DE QUALITE DANS LES ORGANISATIONS INTERNATIONALES SPECIALISEES
By Charles Leben Brussels: Emile Bruylant. 1979. Pp. 410. …
Recent Decisions, William W. Allen, Alexander A. Hassani, Peter A. Schuller
Recent Decisions, William W. Allen, Alexander A. Hassani, Peter A. Schuller
Vanderbilt Journal of Transnational Law
INCOME TAX--LIQUIDATION OF FOREIGN CORPORATIONS--SHAREHOLDERS IN A LIQUIDATING FOREIGN CORPORATION MUST INCLUDE IN THE CORPORATION'S EARNINGS AND PROFITS ACCOUNT THE AMOUNT OF RECAPTURED EXCESS DEPRECIATION REALIZED UPON THE SALE OF ITS ASSETS
William W. Allen
CUSTOMS DUTIES--ANTIDUMPING ACT OF 1921--THE SECRETARY OF THE TREASURY HAS No AUTHORITY TO TERMINATE A WITH-HOLDING OF APPRAISEMENT PRIOR TO THE PUBLICATION OF A DUMPING FINDING BASED ON A LIKELIHOOD OF INJURY DETERMINATION BY THE INTERNATIONAL TRADE COMMISSION
Alexander A. Hassani
INTERNATIONAL BANKING--BANKRUPTCY-FOREIGN BANKS NEITHER REGULATED BY NOR LICENSED To Do BUSINESS IN THE UNITED STATES MAY FILE FOR VOLUNTARY BANKRUPTCY UNDER THE NATIONAL BANKRUPTCY …
Books Received, Journal Staff
Books Received, Journal Staff
Vanderbilt Journal of Transnational Law
A Practical Guide to U.S. Taxation of Overseas Americans
By Thomas E. Johnson
London: Raftwain Ltd., 1977. Pp. 311. $25.00.
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The Impact of International Organizations on Legal and Institutional Changes in the Developing Countries
New York: International Legal Center, 1977. Pp. 275.
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U.S. Customs Tariffs and Trade
By Eugene T. Rossides
Washington, D.C.: The Bureau of National Affairs, Inc., 1977. Pp. 826. $45.00.
The Steel Products Decision: An Inquiry Into The Treatment Of The Value-Added Tax Under The Countervailing Duty Law, Charles L. Chambers
The Steel Products Decision: An Inquiry Into The Treatment Of The Value-Added Tax Under The Countervailing Duty Law, Charles L. Chambers
Vanderbilt Journal of Transnational Law
It is not often that one small clause in a tariff act becomes a major issue between domestic producers and the firms which import competitive foreign goods, a major issue in trade talks between the United States and the European Community, and a bone of contention between the Congress and the Executive Branch. Yet, section 303 of the Tariff Act of 1930 has done just that and no solution to the issues it has raised is in sight...
Section 303 of the Tariff Act of 1930 is simple enough on its face. It imposes a countervailing duty on any goods …
The Role Of The Corn Products Doctrine In Foreign Exchange Transactions, Charles H. Manning
The Role Of The Corn Products Doctrine In Foreign Exchange Transactions, Charles H. Manning
Vanderbilt Journal of Transnational Law
Exchange rate gain or loss may result from fluctuations of exchange rates or from formal governmental action such as revaluation and devaluation. In evaluating the significance of foreign exchange transactions and their tax consequences, the types of transactions that produce exchange rate gain or loss must be distinguished. The first type of transaction is currency speculation in which exchange rate gain or loss is the only profit or loss realized. The second type of transaction involves the purchase and sale of inventory in which the exchange rate gain or loss is ancillary to the monetary gain or loss realized on …