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Articles 1 - 9 of 9

Full-Text Articles in Law

The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum Nov 2014

The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum

Georgia Journal of International & Comparative Law

No abstract provided.


Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver Oct 2014

Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver

Georgia Journal of International & Comparative Law

No abstract provided.


Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas Oct 2014

Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas

Georgia Journal of International & Comparative Law

No abstract provided.


Organizations, Reorganizations, Amalgamations, Divisions And Dissolutions: Cross-Border Assets, Double Taxation And Potential Relief Under The U.S.-Canada Tax Treaty, Catherine A. Brown, Christine Manolakas Oct 2014

Organizations, Reorganizations, Amalgamations, Divisions And Dissolutions: Cross-Border Assets, Double Taxation And Potential Relief Under The U.S.-Canada Tax Treaty, Catherine A. Brown, Christine Manolakas

Georgia Journal of International & Comparative Law

No abstract provided.


For Sale--One Level 5 Barbarian For 94,800 Won: The International Effects Of Virtual Property And The Legality Of Its Ownership, Alisa B. Steinberg Oct 2014

For Sale--One Level 5 Barbarian For 94,800 Won: The International Effects Of Virtual Property And The Legality Of Its Ownership, Alisa B. Steinberg

Georgia Journal of International & Comparative Law

No abstract provided.


A Comparison Of Corporate Taxation In The United States And Germany: Different Ways Up The Mountain, Walter D. Schwidetzky Sep 2014

A Comparison Of Corporate Taxation In The United States And Germany: Different Ways Up The Mountain, Walter D. Schwidetzky

Georgia Journal of International & Comparative Law

No abstract provided.


Beer, Liquor, Or A Little Bit Of Both? Getting To The Bottom Of Properly Classifying Flavored Malt Beverages In The United States And Australia, Bryan A. Schivera Sep 2014

Beer, Liquor, Or A Little Bit Of Both? Getting To The Bottom Of Properly Classifying Flavored Malt Beverages In The United States And Australia, Bryan A. Schivera

Georgia Journal of International & Comparative Law

No abstract provided.


Tax Consequences Of Distributing Equity Compensation Rights In Divorce, Gregg Polsky, Jeffrey D. Fisher, Zachry R. Potter Jan 2014

Tax Consequences Of Distributing Equity Compensation Rights In Divorce, Gregg Polsky, Jeffrey D. Fisher, Zachry R. Potter

Scholarly Works

This article discusses the federal tax issues arising from the equitable distribution of compensatory stock options and restricted stock in divorce. While the tax consequences of distributing vested options and shares are clear, the treatment of unvested rights is muddled. This article explains the state of the law and provides practical advice to divorce lawyers who confront these issues.


The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble Jan 2014

The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble

Scholarly Works

This Article highlights a flaw in the existing rules regarding partnership tax allocations that has not yet received sufficient attention by existing literature. Namely, the partnership tax allocation rules are implicitly premised on the assumption that partners are unrelated and, thus, transact with each other at arm’s length. As a result, related partners can and do devise tax allocation schemes that exploit the gap in the current partnership tax allocation rules to achieve unwarranted tax savings.

This Article proposes to end this abuse by disallowing special allocations among related partners. Under the proposal, allocations among related partners would be required …