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Oecd Project On Harmful Tax Practices, Hugh J. Ault Dec 2011

Oecd Project On Harmful Tax Practices, Hugh J. Ault

Hugh J. Ault

Materials presented in conjunction with a keynote speech delivered on May 15, 2003 at a congress on Tax Competition, organized by the European Tax College and held at Tilburg University, the Netherlands.


Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault Dec 2011

Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault

Hugh J. Ault

In this Article, Professor Ault begins with an examination of the evolution of treaty principles for the allocation of and restrictions on international taxing jurisdiction. He then focuses on how economically based principles dealing with the taxation of international income affect treaty policy and presents the basic structural provisions involving the taxation of foreign income and foreign investors that emerge from domestically enacted or proposed integration systems. The technical aspects of the actual treaty practices that have been implemented with respect to integration systems are then related to the theoretical discussion. Professor Ault concludes with an examination of the implications ...


Taxation And Non-Discrimination: A Reconsideration, Hugh J. Ault, Jacques Sasseville Dec 2011

Taxation And Non-Discrimination: A Reconsideration, Hugh J. Ault, Jacques Sasseville

Hugh J. Ault

No abstract provided.