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Taxation-Transnational Commons™

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

2015

Discipline
Institution
Keyword
Publication
Publication Type

Articles 31 - 35 of 35

Full-Text Articles in Taxation-Transnational

The Joint Venture And Related Contract Laws Of Mainland China And Taiwan: A Comparative Analysis, Clyde D. Stoltenberg, David W. Mcclure Jan 2015

The Joint Venture And Related Contract Laws Of Mainland China And Taiwan: A Comparative Analysis, Clyde D. Stoltenberg, David W. Mcclure

Georgia Journal of International & Comparative Law

No abstract provided.


Defining A Country's "Fair Share" Of Taxes, Adam H. Rosenzweig Jan 2015

Defining A Country's "Fair Share" Of Taxes, Adam H. Rosenzweig

Florida State University Law Review

The international tax regime is facing a defining moment. As stories of multinational companies expatriating and shifting income around the world with seeming impunity continue to emerge, the question of how to divide the international tax base among the countries of the world increasingly draws attention from policy-makers and academics. To date, however, the debate has tended to devolve into one over the two traditional tools used to divide worldwide tax base—transfer pricing and formulary apportionment. This Article demonstrates that such focus is misplaced on the instruments of dividing the worldwide tax base rather than on first principles. Instead, this …


Net Operating Losses And Mistakes In Closed Tax Years, James R. Gadwood Jan 2015

Net Operating Losses And Mistakes In Closed Tax Years, James R. Gadwood

NYLS Law Review

No abstract provided.


School Of Hark Knocks - The Impact Of The Nfl Concussion Litigation, Elise Michael Jan 2015

School Of Hark Knocks - The Impact Of The Nfl Concussion Litigation, Elise Michael

Cardozo Arts & Entertainment Law Journal

No abstract provided.


Who Invented The Single Tax Principle?: An Essay On The History Of Us Treaty Policy, Reuven S. Avi-Yonah Jan 2015

Who Invented The Single Tax Principle?: An Essay On The History Of Us Treaty Policy, Reuven S. Avi-Yonah

Articles

In 1997, I wrote an article on the international tax challenges posed by the then-nascent electronic commerce, in which I suggested that the international tax regime is based on two principles: the benefits principle and the single tax principle. The benefits principle states that active (business) income should be taxed primarily by the country of source, and passive (investment) income should be taxed primarily by the country of residence. This is the famous compromise reached by the four economists at the foundation of the regime in 1923 and is not particularly controversial. It is embodied in every one of the …