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Articles 1 - 30 of 35
Full-Text Articles in Taxation-Transnational
Designing A 21st Century Corporate Tax – An Advance U.S. Minimum Tax On Foreign Income And Other Measures To Protect The Base, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Designing A 21st Century Corporate Tax – An Advance U.S. Minimum Tax On Foreign Income And Other Measures To Protect The Base, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship
The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This article continues our exploration of second best international tax reforms that would protect the U.S. corporate tax base and have some likelihood of adoption. In this case, we consider how a U.S. minimum tax on foreign income earned by a controlled foreign corporation should be designed to protect the United States against erosion of its corporate income tax base and to combat tax competition by low-tax intermediary countries. In the authors’ view, a minimum tax should be an interim levy that preserves the residual U.S. tax …
Too Much Collateral Damage; Fatca: The Well-Intentioned, Yet Misguided And Unconstitutional, Tax Law, Zac Delap
Too Much Collateral Damage; Fatca: The Well-Intentioned, Yet Misguided And Unconstitutional, Tax Law, Zac Delap
Journal of the National Association of Administrative Law Judiciary
This paper will examine FATCA in five parts: beginning with an introduction in Part I, Part II will provide the pertinent background that gave rise to the law, Part III will present the essential elements of FATCA, Part IV will offer pertinent liberty and constitutional arguments against FATCA, and Part V will analyze each argument's possibility of succeeding.
Of More Than Usual Interest: The Taxing Problem Of Debt Principal, Charlene D. Luke
Of More Than Usual Interest: The Taxing Problem Of Debt Principal, Charlene D. Luke
Seattle University Law Review
Leverage is an essential but often troubling component of the U.S. market. The financial crisis highlighted the risks and complexity of a leverage web that includes flesh-and-blood people from all walks of life and paper people from all corners of the business and investment world. In the tax area, the potentially problematic incentive effects of interest deductibility have long engaged a wide array of tax commentators and policymakers. While interest deductibility rightly receives widespread scrutiny, a more comprehensive approach to leverage is needed. This Article focuses on the surprisingly complicated tax treatment of cash (and cash equivalent) borrowings. This Article …
International Tax Considerations: Inbound & Outbound, Seth Green, Monica Zubler
International Tax Considerations: Inbound & Outbound, Seth Green, Monica Zubler
William & Mary Annual Tax Conference
No abstract provided.
International Tax Considerations: Inbound & Outbound (Slides), Seth Green
International Tax Considerations: Inbound & Outbound (Slides), Seth Green
William & Mary Annual Tax Conference
No abstract provided.
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Georgia Journal of International & Comparative Law
No abstract provided.
Offshore Web-Based Gambling Accounts Are Subject To Fbar, Min (Megan) K. Park
Offshore Web-Based Gambling Accounts Are Subject To Fbar, Min (Megan) K. Park
The Contemporary Tax Journal
No abstract provided.
Reforming The Regulation Of Political Advocacy By Charities: From Charity Under Siege To Charity Under Rescue?, Adam Parachin
Reforming The Regulation Of Political Advocacy By Charities: From Charity Under Siege To Charity Under Rescue?, Adam Parachin
Chicago-Kent Law Review
A newly elected liberal federal government in Canada has pledged to reform the legal distinction between charity and politics. This paper provides context to this reform initiative, linking it to a controversial political activities audit program funded by the former conservative federal government. It identifies three distorting ideas about charity—that charity can be understood as a tax expenditure, economic or neutral concept—that should be eschewed in the reform process. It also identifies three characteristics of charity—the capacity of charities for thought leadership, the pervasiveness of messaging in charitable programming and the distinctiveness of charity and government—that should guide reformers.
European Non-Profit Oversight: The Case For Regulating From The Outside In, Oonagh B. Breen
European Non-Profit Oversight: The Case For Regulating From The Outside In, Oonagh B. Breen
Chicago-Kent Law Review
When it comes to the regulation of non-profits, the European Commission experiences many of the same pressures and constraints faced by national charity regulators. It suffers, however, from an added disadvantage in that, arguably, it lacks jurisdictional competence to regulate non-profits qua non-profits. This article explores the consequences of the Commission’s unsuccessful attempt to secure the passage of its proposal for a European Foundation Statute (“EFS”). Notwithstanding the European Council’s inability to muster the necessary Member State unanimity required to pass the proposal and its subsequent demise, the Commission is still dogged by the problems it identified as giving rise …
Australia – Two Political Narratives And One Charity Regulator Caught In The Middle, Myles Mcgregor-Lowndes
Australia – Two Political Narratives And One Charity Regulator Caught In The Middle, Myles Mcgregor-Lowndes
Chicago-Kent Law Review
After two decades of debate about the regulation of the nonprofit sector, Australia established a national charity regulator in December 2012. The creation of the Australian Charities and Not-for-profits Commission (“ACNC”) had as one of its objectives to reduce red tape, and to increase clarity by enacting a statutory definition of charity. Less than two years later, a new government proposed to abolish the ACNC, also in the name of reducing red tape. There appears to be a paradox—or at least diametrically opposed views about red tape reduction and how it can be achieved. With the government nearly two-thirds through …
The Charity Commission For England And Wales: A Fine Example Or Another Fine Mess?, Debra Morris
The Charity Commission For England And Wales: A Fine Example Or Another Fine Mess?, Debra Morris
Chicago-Kent Law Review
The ability of the Charity Commission for England and Wales to regulate the charitable sector effectively has been repeatedly called into question in recent years. At the same time, public sector funding cuts have led to its budget being almost halved in real terms since 2007/08. Numerous official reviews and inquiries into its effectiveness have highlighted its weaknesses and raised concerns about it failing to take sufficient action to prevent abuses of charitable status. In response to the Commission’s claims that it lacks sufficient legal powers to deal with such abuse, new legislation has been passed which will fill some …
The Contemporary Tax Journal Volume 5, No. 1 – Spring/Summer 2015
The Contemporary Tax Journal Volume 5, No. 1 – Spring/Summer 2015
The Contemporary Tax Journal
No abstract provided.
Host Country Taxation Of Transfer Of Technology Transactions, Guillermo Cabanellas, Luis Bertone
Host Country Taxation Of Transfer Of Technology Transactions, Guillermo Cabanellas, Luis Bertone
Georgia Journal of International & Comparative Law
No abstract provided.
Proposed Congressional Limitations On State Taxation Of Multinational Corporations, Kristen Gustafson
Proposed Congressional Limitations On State Taxation Of Multinational Corporations, Kristen Gustafson
Georgia Journal of International & Comparative Law
No abstract provided.
Taxation Aspects Of Foreign Investments In India, Udai V. Singh
Taxation Aspects Of Foreign Investments In India, Udai V. Singh
Georgia Journal of International & Comparative Law
No abstract provided.
Sovereign Immunity - Taxation - Residence Of Foreign Sovereign Diplomatic And Consular Staff Is Immune From Taxation Under A Bilateral Agreement And The Foreign Sovereign Immunities Act, Maija S. Blaubergs
Georgia Journal of International & Comparative Law
No abstract provided.
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Georgia Journal of International & Comparative Law
No abstract provided.
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Georgia Journal of International & Comparative Law
No abstract provided.
United States Bilateral Investment Treaties: Egypt And Panama, Deidre A. Cody
United States Bilateral Investment Treaties: Egypt And Panama, Deidre A. Cody
Georgia Journal of International & Comparative Law
No abstract provided.
Failed Efforts Of The Nitaqat: An Examination Of The New Saudization Initiative Aimed At Easing Unemployment Issues In Saudi Arabia, Feida Zhao
Cardozo Journal of International and Comparative Law
No abstract provided.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Georgia Journal of International & Comparative Law
No abstract provided.
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva
Georgia Journal of International & Comparative Law
No abstract provided.
Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology, Gerald J. Pels
Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology, Gerald J. Pels
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne
Georgia Journal of International & Comparative Law
No abstract provided.
All Or Nothing? The Obama Budget Proposals And Beps, Reuven S. Avi-Yonah
All Or Nothing? The Obama Budget Proposals And Beps, Reuven S. Avi-Yonah
Articles
There is a wide bipartisan consensus that the U.S. international tax regime is broken. We have the highest corporate tax in the OECD, which at 35 percent imposes a real burden on corporations earning mostly U.S.-source income. At the same time, U.S.-based multinationals pay very low effective tax rates on foreign-source income earned through their subsidiaries, leading to a strong incentive to shift profits out of the United States. Finally, the United States is among the few countries to fully tax dividends paid by foreign subsidiaries to their domestic parents, leading to the “trapped income” phenomenon in which $2 trillion …
Disc To Fsc: A Small Business Alternative?, Scott J. Klosinski
Disc To Fsc: A Small Business Alternative?, Scott J. Klosinski
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed, Phil Conner
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth
Georgia Journal of International & Comparative Law
No abstract provided.
New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers
New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers
Georgia Journal of International & Comparative Law
No abstract provided.
Arbitration - Arbitrability Of Antitrust Claims Arising From An International Commercial Contract - Mitsubishi Motors Corp. V. Soler Chrysler-Plymouth, Inc., 105 S. Ct. 3346 (1985)., William L. Blagg
Georgia Journal of International & Comparative Law
No abstract provided.