Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Articles 1 - 9 of 9

Full-Text Articles in Law

Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah Dec 2000

Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah

Articles

This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.


Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault Sep 2000

Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault

Hugh J. Ault

No abstract provided.


A Framework On Consumption Taxes And Their Impact On International Trade, Jane L. Seigendall May 2000

A Framework On Consumption Taxes And Their Impact On International Trade, Jane L. Seigendall

Penn State International Law Review

No abstract provided.


It's A Wonderful Life Insurance Policy: Determining The Correct Theory To Tax The Employee In Employer-Pay-All Equity Split-Dollar Life Insurance Arrangements, I Jay Katz Jan 2000

It's A Wonderful Life Insurance Policy: Determining The Correct Theory To Tax The Employee In Employer-Pay-All Equity Split-Dollar Life Insurance Arrangements, I Jay Katz

Irwin J Katz

A look at the taxation of split-dollar life insurance at the height of its popularity.


On The Frontier Of Procedural Innovation: Advance Pricing Agreements And The Struggle To Allocate Income For Cross Border Taxation, Diane M. Ring Jan 2000

On The Frontier Of Procedural Innovation: Advance Pricing Agreements And The Struggle To Allocate Income For Cross Border Taxation, Diane M. Ring

Michigan Journal of International Law

This paper outlines a recent procedural innovation in the tax area, the Advance Pricing Agreement Program ("APA" program), and evaluates its success. Such a case study can play a significant role in linking procedural innovation to the broader issues of administrative law theory and regulatory reform. For example, a working model such as the APA program, built on flexibility and creativity, may support administrative theories advocating discretion, flexibility, and experimentation. Conversely, some interest group theories of regulation (e.g., public choice theory), can prompt critical examination of reforms like APAs that exhibit limited openness to scrutiny. The APA program is ...


Globalization, Tax Competition, And The Fiscal Crisis Of The Welfare State, Reuven S. Avi-Yonah Jan 2000

Globalization, Tax Competition, And The Fiscal Crisis Of The Welfare State, Reuven S. Avi-Yonah

Articles

This Article examines the increased use of tax incentives as weapons in the international competition to attract investment. Professor Avi-Yonah argues that the establishment of tax havens allows large amounts of capital to go untaxed, depriving both developed and developing countries of revenue and forcing them to rely on forms of taxation less progressive than the income tax. He points to social insurance programs, many of which are already on uncertain courses as aging populations imperil their fiscal health, as likely to bear the brunt of the revenue loss that tax havens cause. Professor Avi-Yonah contends that both economic efficiency ...


Commentary (Response To Article By H. David Rosenbloom), Reuven S. Avi-Yonah Jan 2000

Commentary (Response To Article By H. David Rosenbloom), Reuven S. Avi-Yonah

Articles

David Rosenbloom has delivered an important lecture on an important topic:' whether exploiting differences between the tax system of two different jurisdictions to minimize the taxes paid to either or both ("international tax arbitrage") is a problem, and if so, whether anything can be done about it in a world without a "world tax organization." As Rosenbloom states, international tax arbitrage is "the planning focus of the future,"2 and recently has been the focus of considerable discussion and debate (for example, upon the promulgation and subsequent withdrawal under fire of Notice 98-11).3 Rosenbloom's lecture is one of ...


Tax Competition: What (If Anything) To Do About It?, Hugh Ault Dec 1999

Tax Competition: What (If Anything) To Do About It?, Hugh Ault

Hugh J. Ault

No abstract provided.


Internet: Taxar Ou Não Taxar?, Ivo T. Gico Dec 1999

Internet: Taxar Ou Não Taxar?, Ivo T. Gico

Ivo Teixeira Gico Jr.

O artigo demonstra a opinião do autor acerca de manifestações sobre tributação da internet, sustentando o potencial nocivo à democratização da informação. The article demonstrates the author's opinion about taxing the Internet and its potential harm to the democratization of information.