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- Collecting tax judgments in foreign court (1)
- Corporate valuation (1)
- Creditable tax (1)
- Defining a permanent establishment (1)
- Foreign income taxation (1)
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- Foreign tax credits (1)
- Historical earnings vs. expected value of earnings (1)
- Hosting out-of-state servers (1)
- Income allocation among jurisdictions (1)
- International transactions (1)
- Internet sales (1)
- Int’l tax neutrality (1)
- Nexus (1)
- Privatization of British utilities (1)
- State & federal taxation (1)
- Taxing software in the cloud (1)
- UK Windfall Profit Tax Act of 1997 (1)
Articles 1 - 2 of 2
Full-Text Articles in Law
The Taxation Of Cloud Computing And Digital Content, David Shakow
The Taxation Of Cloud Computing And Digital Content, David Shakow
All Faculty Scholarship
“Cloud computing” raises important and difficult questions in state tax law, and for Federal taxes, particularly in the foreign tax area. As cloud computing solutions are adopted by businesses, items we view as tangible are transformed into digital products. In this article, I will describe the problems cloud computing poses for tax systems. I will show how current law is applied to cloud computing and will identify the difficulties current approaches face as they are applied to this developing technology.
My primary interest is how Federal tax law applies to cloud computing, particularly as the new technology affects international transactions. …
Economic And Legal Arguments In Ppl V. Commissioner, Michael S. Knoll
Economic And Legal Arguments In Ppl V. Commissioner, Michael S. Knoll
All Faculty Scholarship
In late February 2013, the U.S. Supreme Court will hear oral argument in PPL Corp. v. Commissioner. The Court took that case, which involves a claim by a U.S. corporation for foreign tax credits for taxes paid in accordance with the 1997 U.K. Windfall Profit Tax Act, in order to resolve a conflict between the Third Circuit, which denied the credit in PPL, and the Fifth Circuit, which allowed the credit in Entergy Corp. v. Commissioner. Nominally, the U.K. Act imposed a tax on recently privatized regulated companies of 23 percent of the difference between their estimated …