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Articles 781 - 810 of 1275

Full-Text Articles in Taxation-Transnational

Australia – Two Political Narratives And One Charity Regulator Caught In The Middle, Myles Mcgregor-Lowndes Jul 2015

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 Jul 2015

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 Jul 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 May 2015

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 Apr 2015

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 Apr 2015

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 Apr 2015

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 Apr 2015

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 Apr 2015

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 Apr 2015

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 Apr 2015

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. Mar 2015

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 Mar 2015

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 Mar 2015

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 Mar 2015

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 Mar 2015

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 Feb 2015

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 Feb 2015

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 Feb 2015

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 Feb 2015

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 Jan 2015

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.


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 …


Taxpayers’ Lack Of Standing In International Tax Dispute Resolutions: An Analysis Based On The Hybrid Norms Of International Taxation, Limor Riza Dec 2014

Taxpayers’ Lack Of Standing In International Tax Dispute Resolutions: An Analysis Based On The Hybrid Norms Of International Taxation, Limor Riza

Pace Law Review

This paper examines whether a taxpayer should have “standing” in international dispute resolutions. To answer this question the primary task is to identify the nature of international taxation. In other words, this paper discusses how to classify the field of international taxation. Is it part of public international law, private international law (i.e., conflict of laws), national (domestic) law, or is it a hybrid field that requires specific attention? Making this distinction is vital for resolving disputes when a taxpayer is taxed twice for cross-border transactions in cases where the double tax convention is unclear and both contracting states claim …


The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum Nov 2014

The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum

Georgia Journal of International & Comparative Law

No abstract provided.


The Stored Communications Act And Digital Assets, David Horton Nov 2014

The Stored Communications Act And Digital Assets, David Horton

Vanderbilt Law Review

This Article explores the impact of federal law on a state fiduciary's management of digital assets. It focuses on the lessons from the Stored Communications Act ("SCA'), initially enacted in 1986 as one part of the Electronic Communications Privacy Act. Although Congress designed the SCA to respond to concerns that Internet privacy posed new dilemmas with respect to application of the Fourth Amendment's privacy protections, the drafters did not explicitly consider how the SCA might affect property management and distribution. The resulting uncertainty affects anyone with an email account. While existing trusts and estates laws could legitimately be interpreted to …


Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver Oct 2014

Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver

Georgia Journal of International & Comparative Law

No abstract provided.