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Full-Text Articles in Law
Advance Trade Discounts: A Reprise, Deborah A. Geier
Advance Trade Discounts: A Reprise, Deborah A. Geier
Law Faculty Articles and Essays
Prof. Deborah A. Geier, in a response to a recent article by Robert Willens on advance trade discounts, discusses the differences between the courts' analyses and some academics' approaches to measuring the income tax base properly.
No Credit For Gross Withholding Taxes On Portfolio Investments?, Deborah A. Geier
No Credit For Gross Withholding Taxes On Portfolio Investments?, Deborah A. Geier
Law Faculty Articles and Essays
Prof. Deborah Geier discusses the creditability of foreign gross withholding taxes on portfolio investments.
Dividend Taxation In Europe: When The Ecj Makes Tax Policy, Alvin C. Warren, Michael J. Graetz
Dividend Taxation In Europe: When The Ecj Makes Tax Policy, Alvin C. Warren, Michael J. Graetz
Faculty Scholarship
This article analyzes a complex line of recent decisions in which the European Court of Justice has set forth its vision of a nondiscriminatory system for taxing corporate income distributed as dividends within the European Union. We begin by identifying the principal tax policy issues that arise in constructing a system for taxing cross-border dividends and then review the standard solutions found in national legislation and international tax treaties. Against that background, we examine in detail a dozen of the Court's decisions, half of which have been handed down since 2006. Our conclusion is that the ECJ is applying a …