Open Access. Powered by Scholars. Published by Universities.®
- Discipline
-
- Tax Law (18)
- Business Organizations Law (14)
- Taxation-Federal (13)
- Comparative and Foreign Law (7)
- International Law (7)
-
- Banking and Finance Law (4)
- International Trade Law (4)
- Business (3)
- Economics (3)
- Law and Economics (3)
- Securities Law (3)
- Social and Behavioral Sciences (3)
- Taxation (3)
- Transnational Law (3)
- European Law (2)
- International Business (2)
- Jurisdiction (2)
- Accounting Law (1)
- Business Law, Public Responsibility, and Ethics (1)
- Commercial Law (1)
- Conflict of Laws (1)
- Corporate Finance (1)
- Development Studies (1)
- Economic Policy (1)
- International Relations (1)
- Legal Writing and Research (1)
- Legislation (1)
- Natural Resources Law (1)
- Institution
-
- University of Michigan Law School (23)
- University of Maryland Francis King Carey School of Law (3)
- Notre Dame Law School (2)
- Boston University School of Law (1)
- Columbia Law School (1)
-
- Florida State University College of Law (1)
- Northwestern Pritzker School of Law (1)
- Technological University Dublin (1)
- University of Florida Levin College of Law (1)
- University of Georgia School of Law (1)
- University of Miami Law School (1)
- University of Nebraska - Lincoln (1)
- Vanderbilt University Law School (1)
- Washington and Lee University School of Law (1)
- Publication Year
- Publication
-
- Articles (18)
- Faculty Scholarship (4)
- Book Chapters (2)
- Journal Articles (2)
- Michigan Journal of International Law (2)
-
- Books/Book Chapters (1)
- Columbia Center on Sustainable Investment Staff Publications (1)
- Dissertations and Doctoral Documents, University of Nebraska-Lincoln, 2023– (1)
- Florida State University Law Review (1)
- Georgia Journal of International & Comparative Law (1)
- Michigan Law Review (1)
- Northwestern Journal of International Law & Business (1)
- UF Law Faculty Publications (1)
- University of Miami Law Review (1)
- Vanderbilt Journal of Transnational Law (1)
- Washington and Lee Law Review (1)
- Publication Type
Articles 31 - 39 of 39
Full-Text Articles in Taxation-Transnational
Closing The International Tax Gap, Joseph Guttentag, Reuven S. Avi-Yonah
Closing The International Tax Gap, Joseph Guttentag, Reuven S. Avi-Yonah
Book Chapters
In July of 1999, the Justice Department entered into a plea bargain with one John M. Mathewson of San Antonio, Texas. Mr. Mathewson was accused of money laundering through the Guardian Bank and Trust Co. Ltd., a Cayman Islands bank. Mr. Mathewson was chairman and controlling shareholder of Guardian, and in that capacity had access to information on its depositors. In return for a reduced sentence, Mr. Mathewson turned over the names of the persons who had accounts at Guardian. The result was an eye-opener: The majority of the accounts were beneficially owned by U.S. citizens, and the reason they …
Tax Competition: Harmful To Whom?, Michael Littlewood
Tax Competition: Harmful To Whom?, Michael Littlewood
Michigan Journal of International Law
The aim of this paper is to examine the theory that it is both desirable and feasible to prevent less-developed countries from operating preferential tax regimes (that is, offering tax incentives) as a means of attracting foreign investment.
For Haven's Sake: Reflections On Inversion Transactions, Reuven S. Avi-Yonah
For Haven's Sake: Reflections On Inversion Transactions, Reuven S. Avi-Yonah
Articles
This article discusses “inversion” transactions, in which a publicly traded U.S. corporation becomes a subsidiary of a newly established tax haven parent corporation. In the last three years, an increasing number of these transactions have been taking place, undeterred by the shareholderlevel tax imposed by the IRS on them in 1994. The article first discusses the reasons for the increasing popularity of the transactions and the tax goals they aim at achieving (primarily avoiding subpart F and U.S. earnings stripping). The article then discusses the tax policy implications of these transactions. In the short run, the article suggests that the …
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Globalization And Tax Competition: Implications For Developing Countries, Reuven S. Avi-Yonah
Articles
The current age of globalization can be distinguished from the previous one (from 1870 to 1914) by the much higher mobility of capital than labor (in the previous age, before immigration restrictions, labor was at least as mobile as capital). This increased mobility has been the result of technological changes (the ability to move funds electronically), and the relaxation of exchange controls. The mobility of capital has led to tax competition, in which sovereign countries lower their tax rates on income earned by foreigners within their borders in order to attract both portfolio and direct investment. Tax competition, in turn, …
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Articles
This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.
Globalization, Tax Competition, And The Fiscal Crisis Of The Welfare State, Reuven S. Avi-Yonah
Globalization, Tax Competition, And The Fiscal Crisis Of The Welfare State, Reuven S. Avi-Yonah
Articles
This Article examines the increased use of tax incentives as weapons in the international competition to attract investment. Professor Avi-Yonah argues that the establishment of tax havens allows large amounts of capital to go untaxed, depriving both developed and developing countries of revenue and forcing them to rely on forms of taxation less progressive than the income tax. He points to social insurance programs, many of which are already on uncertain courses as aging populations imperil their fiscal health, as likely to bear the brunt of the revenue loss that tax havens cause. Professor Avi-Yonah contends that both economic efficiency …
The United States' Response To Tax Havens: The Foreign Base Company Services Income Of Controlled Foreign Corporations, Eric T. Laity
The United States' Response To Tax Havens: The Foreign Base Company Services Income Of Controlled Foreign Corporations, Eric T. Laity
Northwestern Journal of International Law & Business
This article is a detailed study of the taxation by the United States of foreign base company services income. Foreign base company services in- come is defined generally as the income derived by a controlled foreign corporation from the performance of services for a related person.2 Con- trolled foreign corporations, in turn, generally are the foreign subsidiaries of U.S. parent corporations.3 A controlled foreign corporation's foreign base company services income is taxed to its U.S. parent corporation, subject to various exclusions and qualifications. This article defines the class of sus- pect relationships between the controlled foreign corporation and its related …
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.
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Articles
In 1985, nonbank U.S. multinational companies employed 24.5 million workers, had worldwide sales of almost $3.5 trillion, and net income of $150 billion on assets of $4.2 trillion. The foreign (non-U.S.) affiliates of these companies had 6.4 million employees, $900 billion of those sales, and $43 billion of net income, with assets of $838 billion. United States multinationals accounted for roughly three-quarters of total American merchandise exports in 1985 and half of total imports, with approximately 40 percent of each category arising from transfers within U.S. multinationals between American parent firms and their own foreign affiliates. And 1985 is widely …