Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 4 of 4
Full-Text Articles in Taxation-Transnational
Transfer Pricing, Anders Leif Allvin
Transfer Pricing, Anders Leif Allvin
LLM Theses and Essays
Transfer pricing is one of the principal international taxation issues of the 1990s and potentially of future decades as well. For corporate enterprises, it can be difficult enough to do business in just one country, but it gets even more complex when they go international. The growth of multinational enterprises (MNEs) creates complex taxation issues for both the tax administrations as well for the MNE. Transfer pricing concerns allocation of income earned within affiliated corporate groups in different countries, which must satisfy tax authorities that they are not evading taxes through the use of transfer pricing. The main problem with …
Debt Instruments' Tax Treatment In Corporate Mergers And Acquisitions, Tae Oon Jang
Debt Instruments' Tax Treatment In Corporate Mergers And Acquisitions, Tae Oon Jang
LLM Theses and Essays
The increase of merger and acquisition(M&A) activity since 1992 has resulted mainly from a domestic economic recovery. The current M&A trend shows that M&A is still an important means of enhancing many corporations' competitive power and of stimulating growth in such areas as computer software and services, wholesale and distribution, miscellaneous services, banking and finance, and leisure and entertainment. Fundraising for mezzanine-fund financing, which reflects investors' foresight about current and future M&A trends, has also seen rapid growth. After the Tax Reform Act of 1986 and the repeal of the General Utilities doctrine, the elimination of the capital gain preference …
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
LLM Theses and Essays
This thesis is going to describe the different ways the United States and Germany deal with the problem of double taxation in the legal context of corporate distributions to its shareholders in the form of dividends. Tax law is particularly one of the areas of laws that are subject to frequent and often substantial changes. This is true for the German as well as for the U.S. tax laws. Since some of the issues being discussed in the United States today in connection with the corporate tax law are similar if not identical to the issues discussed in Germany before …
An Analysis Of The Nature And Impact Of Legal Complexities Facing United States Corporations Considering Investment Into The New South Africa, Philip R. Mcdougall
An Analysis Of The Nature And Impact Of Legal Complexities Facing United States Corporations Considering Investment Into The New South Africa, Philip R. Mcdougall
LLM Theses and Essays
Due to sanctions imposed against South Africa’s Apartheid government, the South African economy suffered as little international investment was made in the country. With these sanctions lifted following the democratic elections of 1994, South Africa is now an alluring country for international investment. Despite this attractiveness, U.S. corporations face many legal concerns before entering the South African economy. An analysis of these issues is made in the context of American and South African law with solutions proposed in an effort to avoid deterring foreign investment. These concerns include political and non-economic risks that often hinder investment in the African continent, …