Open Access. Powered by Scholars. Published by Universities.®

Taxation-Transnational Commons

Open Access. Powered by Scholars. Published by Universities.®

Articles 1 - 8 of 8

Full-Text Articles in Taxation-Transnational

A Practical Guide To Advising Clients Entering Into Foreign Joint Ventures In The Face Of Changing Tax Laws, Frank R. Ortolani Dec 1993

A Practical Guide To Advising Clients Entering Into Foreign Joint Ventures In The Face Of Changing Tax Laws, Frank R. Ortolani

William & Mary Annual Tax Conference

No abstract provided.


The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green Nov 1993

The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert A. Green

Cornell Law Faculty Publications



Unfunded Mandates, Hidden Taxation, And The Tenth Amendment: On Public Choice, Public Interest, And Public Services, Edward A. Zelinsky Nov 1993

Unfunded Mandates, Hidden Taxation, And The Tenth Amendment: On Public Choice, Public Interest, And Public Services, Edward A. Zelinsky

Articles

Few contemporary issues concern state and local policymakers as intensely as unfunded mandates. Mayors, county executives, city councilmen, and the professional associations representing them routinely argue that the federal and state governments have, in recent years, imposed at an accelerating rate expensive requirements on municipalities without granting corresponding funds for compliance, thereby irresponsibly straining the fiscal capacity of municipalities, hampering their ability to provide essential services, and improperly infringing upon the scope of local control. The complaints of municipal policymakers have provoked a variety of proposals for restraining unfunded mandates: obligatory disclosure of the projected costs of proposed mandates, requirements …


Withholding Net Will Now Catch More Debt Arrangements, Alan Appel Jan 1993

Withholding Net Will Now Catch More Debt Arrangements, Alan Appel

Articles & Chapters

When the U.S. terminated its income tax treaty with the Netherlands Antilles in 1984, there was criticism from U.S. corporations that they were being unfairly kept out of the competitive Eurobond financing market. In order to provide access to the Eurobond market, Congress enacted Section 871(h) to provide an exemption (the “portfolio interest exemption”) from the 30% withholding tax on U.S.-source income earned by a nonresident alien individual or foreign corporation that is not effectively connected with the conduct of a U.S. trade or business. Portfolio interest, under Sections 871(h) and 163(f), is any U.S.-source interest (including original issue discount) …


Did Zarin Have A Tufts Day At A Casino Made Out Of Kirby Lumber?, I Jay Katz Jan 1993

Did Zarin Have A Tufts Day At A Casino Made Out Of Kirby Lumber?, I Jay Katz

Irwin J Katz

No abstract provided.


The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault Dec 1992

The Role Of The Oecd Commentaries In The Interpretation Of Tax Treaties, Hugh Ault

Hugh J. Ault

An updated version appears inIntertax 4 (April 1994): 144-148.


The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault Dec 1992

The 1992 Model Treaty: Treatment Of Computer Software, Hugh Ault

Hugh J. Ault

No abstract provided.


Horizontal And Vertical Equity: The Musgrave/Kaplow Exchange, James R. Repetti, Paul R. Mcdaniel Dec 1992

Horizontal And Vertical Equity: The Musgrave/Kaplow Exchange, James R. Repetti, Paul R. Mcdaniel

James R. Repetti

[Also appears in Tax Law, volume 1, edited by Patricia D. White, 439-454. New York: New York University Press, 1995.]