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Articles 1 - 13 of 13
Full-Text Articles in Law
How Nations Share, Allison Christians
How Nations Share, Allison Christians
Indiana Law Journal
Every nation has an interest in sharing the gains they help create by participating in globalization. Citizens should be very interested in discovering how well their governments fare in claiming an adequate share of this international income stream, since a government that cannot or will not exert its taxing jurisdiction internationally is potentially missing out on a very large and very productive source of revenue. Yet it is all but impossible for citizens to observe exactly how, or how well, their governments navigate this aspect of economic globalization. The vast majority of international tax law plays out in practice through …
Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg
Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg
Washington and Lee Law Review
No abstract provided.
The Contemporary Tax Journal Volume 2, No. 1 – Spring 2012
The Contemporary Tax Journal Volume 2, No. 1 – Spring 2012
The Contemporary Tax Journal
No abstract provided.
New Reporting Requirements For Foreign Financial Assets, Christopher Rossi
New Reporting Requirements For Foreign Financial Assets, Christopher Rossi
The Contemporary Tax Journal
No abstract provided.
The Unjustified Subsidy: Sovereign Wealth Funds The Foreign Sovereign Tax Exemption, Jennifer Bird-Pollan
The Unjustified Subsidy: Sovereign Wealth Funds The Foreign Sovereign Tax Exemption, Jennifer Bird-Pollan
Fordham Journal of Corporate & Financial Law
The taxation of Sovereign Wealth Funds in the United States is outmoded and due for reconsideration. Offering a tax exemption to the billion dollar investment funds owned by foreign governments is both unfair and ineffective. Founded in the principles of sovereign immunity, the foreign sovereign tax exemption, codified in I.R.C. § 892, fails to satisfy the Congressional goals that motivated its creation. This Article explains the current taxation of foreign sovereigns and, by extension, Sovereign Wealth Funds. It then illustrates that the current exemption is simultaneously too broad, providing a tax exemption for activities that are clearly nongovernmental activities, and …
Problems Involving Permanent Establishments: Overview Of Relevant Issues In Today’S International Economy, Leonardo F.M. Castro
Problems Involving Permanent Establishments: Overview Of Relevant Issues In Today’S International Economy, Leonardo F.M. Castro
Global Business Law Review
The present article analyzes the most common problems related to the Permanent Establishment (PE) concept in International Tax in current modern economy, after the booming of e-commerce, the consolidation of the globalization process, and the new attempts to update and improve such concept in double tax treaties. For that purpose, this article addresses the structure of Article 5 of the OECD Model Tax Convention and gives readers an overview of the concepts, definitions, and problems arising from each of the Article 5 paragraphs of such Model Convention. After such overview, it examines the hottest topics in today‟s international economy that …
Piercing The Veil Of Secrecy: Securing Effective Exchange Of Information To Remedy The Harmful Effects Of Tax Havens, Hedda Leikvang
Piercing The Veil Of Secrecy: Securing Effective Exchange Of Information To Remedy The Harmful Effects Of Tax Havens, Hedda Leikvang
Vanderbilt Journal of Transnational Law
The enforcement of tax laws abroad has long posed problems for authorities. However, that enforcement becomes increasingly more problematic when the information necessary for proper enforcement is located within an impenetrable system whose sole purpose is to protect that information from tax authorities in other countries. Although much effort has been expended to remedy the harmful effects of tax havens, few strategies have succeeded. But with the prospects of a record federal deficit and an ever-increasing tax gap, U.S. authorities have begun to look for new ways to strengthen the enforcement of U.S. tax laws abroad. The most prominent of …
Symposium Introduction: Offshore Accounts, Corporate Income Shifting, And Executive Compensation, Leslie Book
Symposium Introduction: Offshore Accounts, Corporate Income Shifting, And Executive Compensation, Leslie Book
Villanova Law Review
No abstract provided.
Some Suggestions For Tax Reform, Michael C. Durst
Some Suggestions For Tax Reform, Michael C. Durst
Villanova Law Review
No abstract provided.
Go West: How The Irs Should Foster Innovation In Its Agents, T. Keith Fogg
Go West: How The Irs Should Foster Innovation In Its Agents, T. Keith Fogg
Villanova Law Review
No abstract provided.
Offshore Accounts: Insider's Summary Of Fatca And Its Potential Future, J. Richard Harvey Jr.
Offshore Accounts: Insider's Summary Of Fatca And Its Potential Future, J. Richard Harvey Jr.
Villanova Law Review
No abstract provided.
The Use Of Voluntary Disclosure Initiatives In The Battle Against Offshore Tax Evasion, Leandra Lederman
The Use Of Voluntary Disclosure Initiatives In The Battle Against Offshore Tax Evasion, Leandra Lederman
Villanova Law Review
No abstract provided.
Ask For Help, Uncle Sam: The Future Of Global Tax Reporting, Susan C. Morse
Ask For Help, Uncle Sam: The Future Of Global Tax Reporting, Susan C. Morse
Villanova Law Review
No abstract provided.