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Articles 1 - 9 of 9
Full-Text Articles in Law
Tax Competition And E-Commerce, Reuven S. Avi-Yonah
Tax Competition And E-Commerce, Reuven S. Avi-Yonah
Articles
In the last four years, there has been increasing concern by developed countries about the potential erosion of the corporate income tax base by "harmful tax competition" (in the European Union since 1997, in the OECD since 1998). However, the data on tax competition available to date present a mixed and somewhat puzzling picture. On the one hand, there is considerable evidence that effective corporate income tax rates in many countries have been declining, and that the worldwide effective tax rates on multinational enterprises (MNEs) have been going down as well. On the other hand, macroeconomic data from developed countries …
Designing A Combined Reporting Regime For A State Corporate Income Tax: A Case Study Of Louisiana, Michael J. Mcintyre, Paull Mines, Richard D. Pomp
Designing A Combined Reporting Regime For A State Corporate Income Tax: A Case Study Of Louisiana, Michael J. Mcintyre, Paull Mines, Richard D. Pomp
Louisiana Law Review
No abstract provided.
Source Of Income Rules And Treaty Relief From Double Taxation Within The Nafta Trading Bloc, Michael S. Schadewald, Tracy A. Kaye
Source Of Income Rules And Treaty Relief From Double Taxation Within The Nafta Trading Bloc, Michael S. Schadewald, Tracy A. Kaye
Louisiana Law Review
No abstract provided.
An International Comparison Of Taxation Of Married Individuals: Is The "Marriage Tax" Unique To The United States?, Ralph Fritzsch, Neal Matthys, Arthur Andersen, Neal Vazante
An International Comparison Of Taxation Of Married Individuals: Is The "Marriage Tax" Unique To The United States?, Ralph Fritzsch, Neal Matthys, Arthur Andersen, Neal Vazante
Mountain Plains Journal of Business and Technology
The "marriage penalty" or "marriage tax" is a topic of considerable current interest. The purposes of this paper are to provide an explanation and brief example of the "marriage tax," a brief history of how it become part of the US tax code, and a comparison of how marital status affects tax liability in three other English speaking countries (Canada, England, and Australia) with progressive income taxes similar to the US.
The Proposed Federal Taxation Of Frequent Flyer Miles Received From Employers: Good Tax Policy But Bad Politics, Dominic L. Daher
The Proposed Federal Taxation Of Frequent Flyer Miles Received From Employers: Good Tax Policy But Bad Politics, Dominic L. Daher
Akron Tax Journal
The purpose of this article is to dissect the plausibility of taxing frequent flyer miles that were earned by employees on employer-paid travel and later used for personal travel. The first issue for resolution is whether the accrual and utilization of frequent flyer miles earned by an employee while on company-paid travel constitutes compensation for services, and hence gross income, within the meaning of I.R.C. § 61(a)(1). The second issue for resolution is whether the accrual and utilization of frequent flyer miles earned by an employee while on company-paid travel constitutes a taxable fringe benefit, and hence gross income, within …
International Tax Competition: An Efficient Or Inefficient Phenomenon?, Mitchell B. Weiss
International Tax Competition: An Efficient Or Inefficient Phenomenon?, Mitchell B. Weiss
Akron Tax Journal
This Article examines the legal and economic implications of this globalization phenomenon. Part I discusses the allocative effect an income tax system has on a particular country's resources. This first part, while focusing only on domestic tax policy, is intended to throw some light on the international issues that are the central focus of this article. So with this background in mind, Part II turns to the international scene, analyzing the efficiency effect international integration is having on the world's income tax systems in general and the U.S.'s income tax system in particular. Finally, Part III considers what the Organisation …
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Articles
The current age of globalization can be distinguished from the previous one (from 1870 to 1914) by the much higher mobility of capital than labor (in the previous age, before immigration restrictions, labor was at least as mobile as capital). This increased mobility has been the result of technological changes (the ability to move funds electronically), and the relaxation of exchange controls. The mobility of capital has led to tax competition, in which sovereign countries lower their tax rates on income earned by foreigners within their borders in order to attract both portfolio and direct investment. Tax competition, in turn, …
Making Sense Of U.S. International Taxation: Six Steps Toward Simplification, Reuven S. Avi-Yonah
Making Sense Of U.S. International Taxation: Six Steps Toward Simplification, Reuven S. Avi-Yonah
Articles
The Joint Committee on Taxation of the U.S. Congress issued a three-volume study in April 2001 entitled Study of the Overall State of the Federal Tax System and Recommendations for Simplification. Among the more than 100 recommendations of the Joint Committee Study, ten relate to international taxation. Of these, only one can be regarded as achieving significant simplification – the proposal to reduce the number of antideferral regimes from six to two. The other recommendations were limited to relatively minor changes of detail in various international provisions. Even these small steps toward simplifying the notoriously complex U.S. international tax …
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Articles
This article analyses the effects of tax competition on developing countries. Since the 1980s, globalization and greater capital mobility have led many developing countries to adopt the policy of competing with one another to attract capital investment. One of the main forms taken by this competition has been the granting of tax holidays and other tax reductions to investing multinationals. This paper reviews the normative arguments for and against this type of tax competition, from a global perspective. It then examines these arguments in depth from the point of view of developing countries. The conclusion in general is that, since …