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Articles 1 - 7 of 7
Full-Text Articles in Taxation-Transnational
Introduction: The Value-Added Tax - A Symposium, Edwin T. Hood
Introduction: The Value-Added Tax - A Symposium, Edwin T. Hood
Faculty Works
On October 22, 1979, Representative Al Ullman, Chairman of the House Ways and Means Committee, introduced H.R. 5665, the Tax Restructuring Act of 1979. Representative Ullman proclaimed the bill, which contains a ten percent value-added tax, as the "largest adjustment in U.S. taxation since 1913." In his statement accompanying the introduction of H.R. 5665, Chairman Ullman states that the overall purpose for the imposition of a value-added tax coupled with reductions in social security and income taxes, is to correct major flaws in the United States economy-namely double digit inflation, declining productivity, inadequate capital formation, and lagging competition with foreign …
Newly Revised Income Tax Treaty With France: A Breakthrough In U.S. Tax Treaty Law, Stephanie H. Simonard
Newly Revised Income Tax Treaty With France: A Breakthrough In U.S. Tax Treaty Law, Stephanie H. Simonard
Northwestern Journal of International Law & Business
In 1979, the United States and France revised their 1967 Income Tax Treaty Developed along the lines of the Organization of Economic Co-Op- eration and Development Model Convention, the revised Treaty adopts a unique method of calculating the U.S. foreign tax credit limitation. The re- vised Treaty changed the definition of "source" of income to permit the for- eign tax credit against what would otherwise be termed "U.S. source income. " In this article, Mrs. Simonard examines the revised Treaty and its effects on U.S. citizens residing in France
New Developments In The Foreign Tax Credit: The Treasury Department Attempts To Define And Income Tax, David F. Nitschke
New Developments In The Foreign Tax Credit: The Treasury Department Attempts To Define And Income Tax, David F. Nitschke
Northwestern Journal of International Law & Business
In order to alleviate the double taxation of income earned overseas by United States taxpayers, the Internal Revenue Code contains aforeign tax credit. This provision, which enables a taxpayer to credit certain foreign taxes he haspaid or accrued, has been reinterpreted recently by the Depart- ment of the Treasury. In this article, Mr. Nitschke discusses several 1978 revenue rulings andproposed regulations issued in 1979 that have altered the definition of aforeign tax that qualifies as an "income tax" and, thereby, have reduced signficantly the kind offorein taxes eligible for the credit. Upon examination ofprior rulings and case law, Mr. Nitschke …
Hoover Company V. Commissioner: A Judicial One Way Street, Raymond J. Jr. Slomski
Hoover Company V. Commissioner: A Judicial One Way Street, Raymond J. Jr. Slomski
Northwestern Journal of International Law & Business
Recently, the tax court in Hoover Company v. Commissioner,' re- fused to apply the Corn Products doctrine3 and found that a corpora- tion's forward sales agreements in foreign currencies were not hedging agreements.4 The court concluded that such sales did not constitute an integral part of the business,5 and thus losses from such transactions fell outside the protection of Corn Products and were afforded capital treat- ment.6 This note will suggest that the Hoover court, in focusing its deci- sion on the form of the taxpayer's transaction (i.e., whether it was a "bona fide" hedge), failed to properly apply the …
Taxation Aspects Of Foreign Investments In India, Udai V. Singh
Taxation Aspects Of Foreign Investments In India, Udai V. Singh
LLM Theses and Essays
This paper will outline, discuss and suggest changes in various provisions of the Income Tax Act, 1961, applying to foreign investments. Chapter II of this paper explores the general underlying principles of the Indian tax system. Chapter III discusses the tax liability of foreign personnel in India and special tax incentives granted to foreign technicians. Chapter IV discusses the system of corporate taxation or “resident” and non-resident” companies and tax liability of foreign collaborators. Special attention is paid to the liability arising out of various trading activities of non-resident companies in India and many problems of judicial determination relating to …
Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris
Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris
Faculty Scholarship
The more one reads about our economy, the more one is baffled and alarmed. Permanent solutions to economic problems are elusive. Treating one financial malaise often aggravates another sector of the economy, necessitating a delicate balancing of conflicting interests. Furthermore, the problems are complicated by the constant influence of foreign forces. Nevertheless, most economists agree that any solution will require enormous funding. Unfortunately, the public has little, if any, confidence in our tax system. Indeed, some tax laws and proposals have been referred to as "obscene" and a "disgrace to the human race." Few quarrel with the aptness of such …
Recent Developments, Benjamin W. Pardue
Recent Developments, Benjamin W. Pardue
Vanderbilt Journal of Transnational Law
In 1967 the British government devalued the pound as against the dollar. The year 1969 witnessed the floating of the German mark. More recently the dollar has fluctuated widely in international money markets. Under presently accepted accounting principles United States multinational corporations are required to convert their foreign assets and liabilities into dollars at the year's end rate of exchange. When a foreign currency is devalued against the dollar, the value of that foreign subsidiary's assets also declines. In a corporation's consolidated financial statement such a drop in value may distract investors from the corporation's operating successes, with a corresponding …