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Taxation-Transnational Commons

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Full-Text Articles in Taxation-Transnational

Taxation Issues Facing The Foreign Athlete Or Entertainer, Debra Dobray, Tim Kreatschman Jan 1988

Taxation Issues Facing The Foreign Athlete Or Entertainer, Debra Dobray, Tim Kreatschman

NYLS Journal of International and Comparative Law

No abstract provided.


The Canadian White Paper On Sales Tax Reform And The Model Value Added Tax Statute For The United States: A Comparative Analysis, Alan Schenk Jan 1988

The Canadian White Paper On Sales Tax Reform And The Model Value Added Tax Statute For The United States: A Comparative Analysis, Alan Schenk

Law Faculty Research Publications

No abstract provided.


Taxation And U.S. Multinational Investment, James R. Hines Jr. Jan 1988

Taxation And U.S. Multinational Investment, James R. Hines Jr.

Articles

In 1985, nonbank U.S. multinational companies employed 24.5 million workers, had worldwide sales of almost $3.5 trillion, and net income of $150 billion on assets of $4.2 trillion. The foreign (non-U.S.) affiliates of these companies had 6.4 million employees, $900 billion of those sales, and $43 billion of net income, with assets of $838 billion. United States multinationals accounted for roughly three-quarters of total American merchandise exports in 1985 and half of total imports, with approximately 40 percent of each category arising from transfers within U.S. multinationals between American parent firms and their own foreign affiliates. And 1985 is widely …


Capital Neutrality And Coordinated Supervision: Lessons For International Securities Regulation From The Law Of International Taxation And Banking, Charles Thelen Plambeck Jan 1988

Capital Neutrality And Coordinated Supervision: Lessons For International Securities Regulation From The Law Of International Taxation And Banking, Charles Thelen Plambeck

Michigan Journal of International Law

Part I of this article provides some background on the legal forces which have influenced globalization and internationalization of the world's securities markets. Part II focuses on the international tax law principle of capital neutrality. Fundamentally, the principle of capital neutrality requires that regulations should not unintentionally direct the movement of capital. Part II analyzes the bases and parameters of the principle of capital neutrality, the experiences of international taxation in applying the principle to a globalizing economy, and the possibilities for applying the principle to international securities regulation. Part III focuses on the international banking law principle of coordinated …


The Status Of United States International Taxation: Another Fine Mess We've Gotten Ourselves Into, Karen V. Kole Jan 1988

The Status Of United States International Taxation: Another Fine Mess We've Gotten Ourselves Into, Karen V. Kole

Northwestern Journal of International Law & Business

United States international tax policy in the 1980s and beyond, where are we going and why? The federal income tax has arguably taken a consistent approach to basic international issues since its inception. To this allegedly well balanced compromise between theory and practicality, an increasingly complex maze of rules has been added without much direction. The result is chaos with little apparent benefit. Contrary to the alleged intent of these piecemeal amendments, the changes have complicated, not simplified, the area of the international tax law. In trying to make an inherently imperfect system perfect, monumental administrative burdens have been imposed …


The Termination Of The United States-Netherlands Antilles Tax Treaty: What Were The Costs Of Ending Treaty Shopping, Frith Crandall Jan 1988

The Termination Of The United States-Netherlands Antilles Tax Treaty: What Were The Costs Of Ending Treaty Shopping, Frith Crandall

Northwestern Journal of International Law & Business

On June 29, 1987 the United States Treasury Department terminated the United States-Netherlands Antilles Tax Treaty (the "Treaty"). The United States and the Netherlands Antilles had attempted to preserve the Treaty for eight years. However, negotiations ended because of a loggerhead over the extent to which the Netherlands Antilles would maintain any tax haven status. Termination of the Treaty was a victory for the United States since third parties to the Treaty could no longer misuse it to evade United States taxes. Furthermore, the termination significantly advanced the continuing United States policy to eliminate "treaty shopping." The purpose of this …


Family Taxation In The United States: The Choice Of Taxable Unit, Hugh Ault Dec 1987

Family Taxation In The United States: The Choice Of Taxable Unit, Hugh Ault

Hugh J. Ault

No abstract provided.