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Articles 1 - 18 of 18
Full-Text Articles in Taxation-Transnational
Fugitives And Agrarians In A World Without Frontiers, Jim Chen
Fugitives And Agrarians In A World Without Frontiers, Jim Chen
Cardozo Law Review
Rien de grand avant l'tat. Let the French have their Colbertisme; Americans hold steadfast their faith in constitutionalism, the unofficial civic religion of the United States. Implicit in originalism, the most rigidly orthodox variant of America's constitutional faith is the belief that the legal world began with the framing of the Constitution. "All things created before me were not eternal": with the Constitution as creation, the American legal imagination need not embrace anything that occurred before 1787.
Expatriation, Double Taxation, And Treaty Override: Who Is Eating Crow Now?, Christine L. Agnew
Expatriation, Double Taxation, And Treaty Override: Who Is Eating Crow Now?, Christine L. Agnew
University of Miami Inter-American Law Review
No abstract provided.
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
University of Miami Law Review
No abstract provided.
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
University of Miami Law Review
No abstract provided.
An Overview Of International Tax Issues, Joseph H. Guttentag
An Overview Of International Tax Issues, Joseph H. Guttentag
University of Miami Law Review
No abstract provided.
Tax Treaty Issues, David R. Tillinghast
Tax Treaty Issues, David R. Tillinghast
University of Miami Law Review
No abstract provided.
Foreign Tax Problems Of U.S. Companies Doing Business In Latin America, Peter D. Byrne
Foreign Tax Problems Of U.S. Companies Doing Business In Latin America, Peter D. Byrne
University of Miami Law Review
No abstract provided.
Structuring Foreign Investment In United States Real Estate, William H. Newton Iii
Structuring Foreign Investment In United States Real Estate, William H. Newton Iii
University of Miami Law Review
No abstract provided.
U.S. Final Transfer Pricing Regulations, John S. Nolan
U.S. Final Transfer Pricing Regulations, John S. Nolan
University of Miami Law Review
No abstract provided.
Source-Basis Taxation Of Derivative Financial Instruments: Some Unanswered Questions, H. David Rosenbloom
Source-Basis Taxation Of Derivative Financial Instruments: Some Unanswered Questions, H. David Rosenbloom
University of Miami Law Review
No abstract provided.
International Criminal Tax Cases, Cono R. Namorato, Scott D. Michel
International Criminal Tax Cases, Cono R. Namorato, Scott D. Michel
University of Miami Law Review
No abstract provided.
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
University of Miami Inter-American Law Review
No abstract provided.
The Continuing Viability Of The Banking And Financial Disc: A Tool For Sheltering Export Finance Income, Ricardo Corona
The Continuing Viability Of The Banking And Financial Disc: A Tool For Sheltering Export Finance Income, Ricardo Corona
University of Miami Inter-American Law Review
No abstract provided.
Model Codes And Tax Technical Assistance: Note On The Revised Edition Of The Basic World Tax Code And Commentary, Richard K. Gordon
Model Codes And Tax Technical Assistance: Note On The Revised Edition Of The Basic World Tax Code And Commentary, Richard K. Gordon
Faculty Publications
No abstract provided.
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Cornell Law Faculty Publications
No abstract provided.
Assessing The Tax Administration Law Of The People's Republic Of China, Kara Phillips, Amy Sommers
Assessing The Tax Administration Law Of The People's Republic Of China, Kara Phillips, Amy Sommers
Faculty Articles
This article discusses the effort of the People's Republic of China (PRC or China) to obtain revenue through taxes rather than through receipt of profits from state enterprises. In order to strengthen the tax system, in 1992 the Standing Committee of the National People's Congress enacted the Law of the People's Republic of China to Administer the Levying and Collection of Taxes (Tax Administration Law). The authors evaluate the PRC’s Tax administration Law, and discuss the factors that influenced the enactment of the Tax Administration Law and the Implementing Regulations. The authors also examine the Tax Administration Law’s general principles, …
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, …
The Structure Of International Taxation: A Proposal For Simplification, Reuven S. Avi-Yonah
The Structure Of International Taxation: A Proposal For Simplification, Reuven S. Avi-Yonah
Articles
The article explains the structure of the international tax regime and offers suggestions for improvement.