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Taxation-Transnational Commons™

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International taxation

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Articles 31 - 35 of 35

Full-Text Articles in Taxation-Transnational

The Interaction Of Tax And Non-Tax Treaties, Robert A. Green Jan 2002

The Interaction Of Tax And Non-Tax Treaties, Robert A. Green

Cornell Law Faculty Publications

This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.


Transfer Pricing, Anders Leif Allvin Jan 1999

Transfer Pricing, Anders Leif Allvin

LLM Theses and Essays

Transfer pricing is one of the principal international taxation issues of the 1990s and potentially of future decades as well. For corporate enterprises, it can be difficult enough to do business in just one country, but it gets even more complex when they go international. The growth of multinational enterprises (MNEs) creates complex taxation issues for both the tax administrations as well for the MNE. Transfer pricing concerns allocation of income earned within affiliated corporate groups in different countries, which must satisfy tax authorities that they are not evading taxes through the use of transfer pricing. The main problem with …


International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah Jan 1997

International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah

Articles

This article submits proposals for taxing the digital economy on the basis of the benefits and single tax principles.


The Forgotten Link: Control In Section 482, Wayne M. Gazur Jan 1994

The Forgotten Link: Control In Section 482, Wayne M. Gazur

Publications

The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.


Recent Developments, Benjamin W. Pardue Jan 1980

Recent Developments, Benjamin W. Pardue

Vanderbilt Journal of Transnational Law

In 1967 the British government devalued the pound as against the dollar. The year 1969 witnessed the floating of the German mark. More recently the dollar has fluctuated widely in international money markets. Under presently accepted accounting principles United States multinational corporations are required to convert their foreign assets and liabilities into dollars at the year's end rate of exchange. When a foreign currency is devalued against the dollar, the value of that foreign subsidiary's assets also declines. In a corporation's consolidated financial statement such a drop in value may distract investors from the corporation's operating successes, with a corresponding …