Open Access. Powered by Scholars. Published by Universities.®
- Institution
- Keyword
-
- Branch profits tax (1)
- Capital export neutrality (1)
- Capital import neutrality (1)
- Capital ownership neutrality (1)
- Circular 230 (1)
-
- Cross-border transactions (1)
- Dividend (1)
- Foreign corporation (1)
- Foreign direct investment (1)
- Foreign tax credits (1)
- Internal Revenue Service (1)
- International competitiveness (1)
- International finance (1)
- International tax (1)
- James hines (1)
- Lawyers (1)
- Mihir desai (1)
- Reportable transactions (1)
- Subsidiary (1)
- Tax (1)
- Tax competition (1)
- Tax incentives (1)
- Ubit (1)
- Unrelated business income tax (1)
Articles 1 - 5 of 5
Full-Text Articles in Law
Taxes And Competitiveness, Michael S. Knoll
Taxes And Competitiveness, Michael S. Knoll
All Faculty Scholarship
Around the world, the tax laws are shaped by concerns with competitiveness. This paper provides a general theory of how taxes impact competitiveness. As part of that theory, this paper also introduces the concept of tax-based competitiveness neutrality. A tax system is competitively neutral when taxes do not cause competitors to change their relative valuations of any investments. This paper then uses that theory to evaluate tax policy in two high profile and important areas. The paper begins by describing two models of competitiveness, called the conduit or new money model and the investor or old money model. The central …
Tax Practice In A Circular Revolution: A Review Of Pli's Circular 230 Deskbook, Bridget J. Crawford
Tax Practice In A Circular Revolution: A Review Of Pli's Circular 230 Deskbook, Bridget J. Crawford
All Faculty Scholarship
This short review essay evaluates the Practicing Law Institute's Circular 230 Deskbook by Jonathan G. Blattmachr, Mitchell M. Gans and Damien Rios. For attorneys, accountants and others who "practice" before the IRS, the Circular 230 Deskbook is a masterful analysis and an important guide to the Internal Revenue Service's labyrinthine rules and regulations governing tax penalties, reportable transactions and the conduct of tax practitioners. Most tax attorneys and accountants have reacted to the recent changes to Circular 230 by appending banner notices to all written communications. Without fully understanding the underlying rules, however, a practitioner cannot be sure that a …
Reforming The Branch Profits Tax To Advance Neutrality, Fred B. Brown
Reforming The Branch Profits Tax To Advance Neutrality, Fred B. Brown
All Faculty Scholarship
Congress enacted the branch profits tax in order to reduce the disparity between the taxation of U.S. subsidiaries and U.S. branches of foreign corporations. The branch profits tax attempts to promote neutrality by subjecting the U.S. branch earnings of a foreign corporation to a second level of U.S. tax upon the deemed remittance of the earnings outside of the U.S. branch. This is to approximate the second-level tax that occurs in the subsidiary setting when a U.S. subsidiary pays dividends to its foreign parent. Unlike the dividend tax in the subsidiary setting, however, the branch profits tax can apply even …
Horizontal And Vertical Equity In Taxation As Constitutional Principles: Germany And The United States Contrasted, Henry Ordower
Horizontal And Vertical Equity In Taxation As Constitutional Principles: Germany And The United States Contrasted, Henry Ordower
All Faculty Scholarship
Explores U. S. Supreme Court and German Constitutional Court decisions that apply their respective constitutions to taxation controversies, especially controversies in matters involving equal protection or due process protection.
Comparative Law Observations On Taxation Of Same-Sex Couples, Henry Ordower
Comparative Law Observations On Taxation Of Same-Sex Couples, Henry Ordower
All Faculty Scholarship
Identifies the various models for addressing the interplay between same sex relationship protections and taxation outside the United States.