Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Bank branch (1)
- Corporate tax (1)
- Corporations (1)
- Dividend (1)
- Foreign bank (1)
-
- Foreign income (1)
- Foreign tax assessment (1)
- Foreign tax credit (1)
- Full Faith and Credit Clause (1)
- Globalization (1)
- Income tax (1)
- Internal Revenue Code (1)
- Internal Revenue Code of 1954 (1)
- Lien (1)
- Liquidation distribution (1)
- Multinational enterprises (1)
- Non-entertainment rule (1)
- Parent corporation (1)
- Revenue (1)
- Section 6321 (1)
- Separate entity theory (1)
- Subsidiary (1)
- Tax evasion (1)
- Tax havens (1)
- Tax rates (1)
- Taxation (1)
- Territoriality (1)
Articles 1 - 4 of 4
Full-Text Articles in Taxation-Transnational
Tax Havens As Producers Of Corporate Law, William J. Moon
Tax Havens As Producers Of Corporate Law, William J. Moon
Michigan Law Review
A review of Christopher M. Bruner, Re-Imagining Offshore Finance: Market-Dominant Small Jurisdictions in a Globalizing Financial World.
Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba
Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba
Michigan Law Review
The Commissioner of Internal Revenue issued jeopardy assessments against the taxpayer, Omar, S.A., a Uruguayan corporation. To avoid payment, Omar began to liquidate its American-held assets by transferring receipts out of the country. Pursuant to its statutory right, under section 6321 of the Internal Revenue Code of 1954, to impose a lien upon all property of a delinquent taxpayer, the United States brought suit against Omar and various New York banks in the domestic and foreign branches of which Omar's funds were deposited. The district court granted a preliminary injunction restraining certain of the banks from transferring any property whether …
Conflict Of Laws-Full Faith And Credit-Extraterritorial Enforcement Of State Revenue Law, Edwin A. Howe Jr.
Conflict Of Laws-Full Faith And Credit-Extraterritorial Enforcement Of State Revenue Law, Edwin A. Howe Jr.
Michigan Law Review
As the operator of a parking lot within plaintiffs city limits, defendant was subject to a ten percent city tax on his gross receipts. He failed to report the whole of his receipts on his monthly tax returns, and plaintiff, the City of Philadelphia, duly notified him of a five thousand dollar deficiency. Defendant had a statutory right to petition for administrative review of the assessment within sixty days, failing which the liability would become fixed and no longer subject to review or appeal. Rather than appealing, defendant removed himself and his assets to New York, thus preventing plaintiff from …
Taxation-Federal Income Tax-Liquidation Distributions Entitled To Both Capital Gains Treatment And Foreign Tax Credit, Lloyd C. Fell
Taxation-Federal Income Tax-Liquidation Distributions Entitled To Both Capital Gains Treatment And Foreign Tax Credit, Lloyd C. Fell
Michigan Law Review
Plaintiff, Associated, is an American corporation whose wholly-owned subsidiary, Automatic, owned all the stock of Filcrest, a Canadian corporation. In 1954 all the assets of Filcrest were distributed to Automatic pursuant to a plan of complete liquidation, accomplished in accordance with Canadian law. In its 1954 consolidated return, plaintiff treated the gain realized on the Filcrest liquidation as a capital gain, and also claimed a foreign tax credit for any Canadian income, war or excess profits taxes which Filcrest had paid over the years to Canada on that part of the liquidation distribution which represented Filcrest's accumulated earnings and profits. …