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Articles 451 - 480 of 595
Full-Text Articles in Taxation-Transnational
Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.
Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.
The Contemporary Tax Journal
No abstract provided.
Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li
Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018
The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018
The Contemporary Tax Journal
No abstract provided.
Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail
Texas A&M Law Review
In early 2016, the International Consortium of Investigative Journalists released a report detailing thousands of leaked documents demonstrating how a Panamanian law firm had, for years, helped wealthy clients conceal their financial activities through the use of offshore shell companies. The Panama Papers, as the leaked documents came to be known, directed renewed attention at the use of shell companies. Shell companies are used by the world’s wealthy and powerful to lower their taxes, but are also used by tax evaders, criminal organizations, and terrorists. While much of the renewed attention has been directed at offshore tax havens such as …
The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean
The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean
Fordham Journal of Corporate & Financial Law
No abstract provided.
Guilty As Charged: Reflections On Tra 17, Reuven S. Avi-Yonah
Guilty As Charged: Reflections On Tra 17, Reuven S. Avi-Yonah
Articles
The international provisions of TRA 17S are in some ways an improvement over TRA 17H, but they are nevertheless deeply flawed. U.S.-based MNEs have accumulated $ 2.6 trillion of low taxed income offshore. This "guilty" income derives not just from IP developed in the United States, but in many cases (for example, Google, Facebook, and Big Pharma) also from exploiting the U.S. consumer market. This is a classic "round tripping" situation in which both the supply side (production) and the demand side (consumption) are in the United States, and yet both TRA 17H and TRA 17S let the guilty parties …
Once More, With Feeling: Tra 17 And Original Intent Of Subpart F, Reuven S. Avi-Yonah, Nir Fishbien
Once More, With Feeling: Tra 17 And Original Intent Of Subpart F, Reuven S. Avi-Yonah, Nir Fishbien
Articles
For the first time since 1913, Congress is considering abandoning the principle that U.S. residents should be subject to tax on all income “from whatever source derived.” Specifically, the proposed tax reform legislation, the Tax Cuts and Jobs Act, would completely exempt from U.S. taxation dividends from controlled foreign corporations. This is therefore a good occasion for considering the reasons we tax those dividends in the first place.
Designing A Legal Regime To Capture Capital Gains Tax On Indirect Transfers Of Mineral And Petroleum Rights: A Practical Guide, Perrine Toledano, John Bush, Jacky Mandelbaum
Designing A Legal Regime To Capture Capital Gains Tax On Indirect Transfers Of Mineral And Petroleum Rights: A Practical Guide, Perrine Toledano, John Bush, Jacky Mandelbaum
Columbia Center on Sustainable Investment Staff Publications
When a local asset (or a right relating to such asset) is sold, a country will generally have jurisdiction to levy a capital gains tax on the sale, both under domestic law and international treaty. This is called taxation of a “direct” transfer of a local asset. However, taxation becomes increasingly complicated when a company located offshore owns the local asset. Further difficulties arise when the local asset is held by a chain of corporations located in tax havens. An “indirect” transfer occurs when the shares of the domestic subsidiary, the shares of the foreign company with a branch in …
Front Matter (Letter From The Editor, Masthead, Etc.)
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017
The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017
The Contemporary Tax Journal
No abstract provided.
Country By Country Reporting Under Beps, Fenny Lei
Country By Country Reporting Under Beps, Fenny Lei
The Contemporary Tax Journal
No abstract provided.
Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng
Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng
The Contemporary Tax Journal
No abstract provided.
U.S. Tax Forms For American Expatriates, Saqib Amin Cpa
U.S. Tax Forms For American Expatriates, Saqib Amin Cpa
The Contemporary Tax Journal
No abstract provided.
The Gordian Knot: How The United States, The European Union, And Organization For Economic Cooperation And Development Took Action Against Corporate Tax Avoidance, Katlyn Twomey
Honors Projects in History and Social Sciences
In 2016, the United States had the highest corporate tax rate in the world. Perhaps, the high tax rate could be why American corporations are holding an estimated $2.5 trillion abroad (Cox 2016). According to a study by the Bureau of Economic Analysis, U.S. firms pay a measly 3% in tax to foreign governments on those profits, rather than the 35% U.S. corporate tax rate. How are these corporations able to legally avoid paying taxes on a large percentage of their profits? Many use various loopholes in the laws to shift profits into other countries or U.S. states referred to …
Nobody’S Stock Compares To Your Own: How Treasury Can Revive Stock Compensation In Cost-Sharing Agreements, Tyler Johnson
Nobody’S Stock Compares To Your Own: How Treasury Can Revive Stock Compensation In Cost-Sharing Agreements, Tyler Johnson
Northwestern University Law Review
In Altera Corp. v. Commissioner, the United States Tax Court invalidated a 2003 Treasury Regulation for failing to meet State Farm’s reasoned decisionmaking standard under the Administrative Procedure Act (APA). Invalidating this specific regulation eliminates one of the federal government’s latest attempts to limit income tax avoidance by some of the world’s largest and wealthiest corporations in the murky world of transfer pricing. This Note demonstrates that the Tax Court’s ruling must be limited to its specific APA holding and argues that Treasury may enact a similar regulation under the existing statutory and regulatory framework of the arm’s length …
Problems With Destination-Based Corporate Taxes And The Ryan Blueprint, Reuven S. Avi-Yonah, Kimberly Clausing
Problems With Destination-Based Corporate Taxes And The Ryan Blueprint, Reuven S. Avi-Yonah, Kimberly Clausing
Articles
With the election of Donald Trump and the Republican Party’s domination of Congress, House Speaker Paul Ryan’s blueprint for fundamental tax reform requires more careful analysis. The Ryan blueprint combines reduced individual rates with a destination-based cash flow type business tax applicable to all businesses. The destination-based business tax at the center of the blueprint has several major problems: It is incompatible with our WTO obligations, it is incompatible with our tax treaties, and it will not eliminate the problems of income shifting and inversions it is designed to address. In addition, these proposals generate vexing technical problems that are …
Putting The Substance Back Into The Economic Substance Doctrine, Nicholas Giordano
Putting The Substance Back Into The Economic Substance Doctrine, Nicholas Giordano
Brooklyn Journal of Corporate, Financial & Commercial Law
The foreign tax credit, which saves U.S. taxpayers from paying both foreign and domestic income taxes on the same income, is critical to facilitating global commerce. However, as savvy taxpayers discover increasingly complicated ways to abuse the foreign tax credit regime through the structuring of business transactions, courts have become increasingly skeptical of the validity of those transactions. Using the economic substance doctrine, a common law doctrine codified in 2010 at I.R.C. § 7701(o), courts will disallow tax benefits stemming from a transaction that is not profitable absent its tax benefits, and which the taxpayer had no incentive to undertake …
Country By Country Reporting And Corporate Privacy: Some Unanswered Questions, Reuven S. Avi-Yonah
Country By Country Reporting And Corporate Privacy: Some Unanswered Questions, Reuven S. Avi-Yonah
Articles
Corporate privacy is an oxymoron. Individuals have a right to privacy, which the Supreme Court has recognized at least since Griswold v. Connecticut (1965). Warren and Brandeis’ famous defense of the right to privacy (1890) clearly applied only to individuals, because only individuals have the kind of feelings that are affected by invasions of privacy. Corporations are legal entities, and the concept of privacy does not apply to them, as the Supreme Court held in 1906. Thus, any objection to making corporate tax returns public cannot rest on the right to privacy. In fact, corporate returns were made public in …
Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute, Padmini Yalamarthi, Fan Wang, Jie Shen, Xuan Hong, Marla Hampton Cpa, Mba, Aaron Grey
Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute, Padmini Yalamarthi, Fan Wang, Jie Shen, Xuan Hong, Marla Hampton Cpa, Mba, Aaron Grey
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.)
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 6, No. 1 – Summer/Fall 2016
The Contemporary Tax Journal Volume 6, No. 1 – Summer/Fall 2016
The Contemporary Tax Journal
No abstract provided.
The Foreign Earned Income Exclusion, Shilpa Balnadu
The Foreign Earned Income Exclusion, Shilpa Balnadu
The Contemporary Tax Journal
No abstract provided.
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd
Georgia Journal of International & Comparative Law
No abstract provided.
The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016
The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016
The Contemporary Tax Journal
No abstract provided.
Analysis Of The Federal Estate Tax, Rachita Kothari
Analysis Of The Federal Estate Tax, Rachita Kothari
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.)
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja
The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja
The Contemporary Tax Journal
No abstract provided.
When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh
When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh
The Contemporary Tax Journal
No abstract provided.
Repeal The Alternative Minimum Tax, Branden Wilson
Repeal The Alternative Minimum Tax, Branden Wilson
The Contemporary Tax Journal
No abstract provided.