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An Equity-Based, Multilateral Approach For Sourcing Income Among Nations, Fred B. Brown Jan 2011

An Equity-Based, Multilateral Approach For Sourcing Income Among Nations, Fred B. Brown

All Faculty Scholarship

The source of income rules used in the United States and elsewhere in large part establish the contours of tax jurisdiction exercised by countries. The source rules play a vital role in the foreign tax credit system applicable to U.S. persons with foreign investment or business activities. The source rules also play a central role in the United States’ exercise of source taxation over foreign persons with U.S. businesses or investments. Other countries likewise use source rules or their equivalent in applying foreign tax credit or territorial systems to their residents and exercising source taxation over nonresidents.

The ...


The Meaning Of 'Enterprise,' 'Business' And 'Business Profits' Under Tax Treaties And Eu Tax Law (Canada), Kim Brooks Jan 2011

The Meaning Of 'Enterprise,' 'Business' And 'Business Profits' Under Tax Treaties And Eu Tax Law (Canada), Kim Brooks

Articles, Book Chapters, & Popular Press

This chapter explores the meaning of business as it is used in Canadian income tax law given the four purposes that concept serves.