Universidad de La Salle, Bogotá
University of Michigan Law School
Schulich School of Law, Dalhousie University
University of Georgia School of Law
University of Michigan Law School
William & Mary Law School
University of Florida Levin College of Law
Reflections From The Brink Of Tax Warfare: Developing Countries, Digital Services Taxes, And An Opportunity For More Just Global Governance With The Oecd’S Two-Pillar Solution,
2022
Boston College Law School
Reflections From The Brink Of Tax Warfare: Developing Countries, Digital Services Taxes, And An Opportunity For More Just Global Governance With The Oecd’S Two-Pillar Solution, Connor L. Smith
Boston College Law Review
Starting in 2016, many countries enacted digital services taxes (DSTs), a turnover tax that applies to digital companies regardless of whether they have a physical presence in the taxing jurisdiction. After the Organization for Economic Cooperation and Development’s Inclusive Framework reached final agreement on its two-pillar solution to tax challenges in a global digital economy, these unilateral measures went on pause. This Note reflects on the recent DST phenomenon, reconceptualizing the DST debate as part of a broader discourse on global governance and globalization. Although DSTs first emerged in developed countries in the European Union, this Note analyzes developing ...
International Tax,
2022
Southern Methodist University
International Tax, Javier Canosa, Aseem Chawla, Pamela A. Fuller, Chandni Javeri, Priyanka Mongia, Jorge Lopez, Marco Ottenwälder, Jan Neugebauer, Eugenio Romita, Guillermo Villaseñor
The Year in Review
No abstract provided.
Cross-Border Real Estate,
2022
Southern Methodist University
Cross-Border Real Estate, Timur Bondaryev, Olga Ivanova, Felipe Isa Castillo, Avikshit Moral, Apurva Kanvinde
The Year in Review
No abstract provided.
What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums,
2022
Northern Illinois University
What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums, John D. Patten
Honors Capstones
What is insurance for the purposes of a tax deduction? The Internal Revenue Code does not define insurance. Without this definition, taxpayers using alternative insurance products to manage their risks must look to case law to determine whether their arrangements count as tax deductible insurance or non-deductible self-insurance. This paper dives into the four prongs of insurance: insurance risk, risk shifting, risk distributing, and commonly accepted notions of insurance. This paper looks to cases that have dealt with the deduction of captive insurance premiums to provide better insight into the practical application of this test. After discussing the evolution of ...
Tax Incentives In Three Common Markets,
2022
Kuwait University School of Law
Tax Incentives In Three Common Markets, Sarah Khaled Alsultan
Georgia Journal of International & Comparative Law
There are three approaches to dealing with tax incentives within common markets: permit them, limit them, or harmonize them. Broadly speaking, the United States (U.S.) follows the first approach, the European Union (EU) adopts the second, and the Gulf Cooperation Council (GCC) pursues the third by harmonizing some tax incentives, particularly those offered to the industrial sector. Unlike the U.S. and EU common markets, where incentives have gained significant scholarly attention, no academic literature exists on the legal framework of tax incentives in GCC common market. This work attempts to compensate for this insufficiency in scholarship and compares ...
Global Partnership Should Be The Way Forward To Combat Money Laundering,
2022
Penn State Dickinson Law
Global Partnership Should Be The Way Forward To Combat Money Laundering, Maame Nyakoa Boateng
Dickinson Law Review
This Comment compares the major anti-money laundering (“AML”) laws in the United States and Iran. This Comment argues that even though the United States is advanced in its compliance approach, without a partnership with countries that are more vulnerable to money laundering attacks, its AML efforts could prove counter-productive because of the inter-connectedness of our world today. Accordingly, this Comment proposes a global partnership between countries with effective AML legislation and countries with less effective AML legislation to combat this complex crime.
International Taxes,
2022
Southern Methodist University
International Taxes, Sunita Doobay, Daniel Gottfried, Christie Galinski, Gagan Kumar, Jorge Lopez, Elinore Richardson, Eugenio Romita, Guillermo Villaseñor
The Year in Review
No abstract provided.
Apple V. European Commission: Losing The War On Corporate International Transfer Pricing,
2022
Northeastern University; Cantley Dietrich, P.C.
Apple V. European Commission: Losing The War On Corporate International Transfer Pricing, Beckett Cantley, Geoffrey Dietrich
Loyola of Los Angeles International and Comparative Law Review
No abstract provided.
Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce,
2022
Depaul University College of Law
Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce, Daniel O'Connor
DePaul Business and Commercial Law Journal
No abstract provided.
Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring,
2022
Drake University Law School
Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring, Doug Bujakowski, Joan Schmit
DePaul Business and Commercial Law Journal
No abstract provided.
The "Business Interruption" Insurance Coverage Conundrum: Covid-19 Presents A Challenge,
2022
University of North Dakota School of Law
The "Business Interruption" Insurance Coverage Conundrum: Covid-19 Presents A Challenge, Paul E. Traynor
DePaul Business and Commercial Law Journal
No abstract provided.
Misalighned Incentives In Markets: Envisioning Finance That Benefits All Of Society,
2022
University of Calgary
Misalighned Incentives In Markets: Envisioning Finance That Benefits All Of Society, Dr. Ryan Clements
DePaul Business and Commercial Law Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2022
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Monsanto: Creator Of Cancer Liability,
2022
DePaul University
Monsanto: Creator Of Cancer Liability
DePaul Business and Commercial Law Journal
No abstract provided.
Impact Of Corporate Response To Controversial Presidential Statements Or Policies,
2022
DePaul University
Impact Of Corporate Response To Controversial Presidential Statements Or Policies
DePaul Business and Commercial Law Journal
No abstract provided.
Comparative Tax Law Guide,
2022
Dalhousie University Schulich School of Law
Comparative Tax Law Guide, Kim Brooks
OER Texts
This extended bibliography is designed to support comparative tax law study by students, policy-makers, and tax practitioners. Studying comparative tax law is pure joy. And in addition to that, it enables you to:
- more deeply understand your own tax system and context;
- learn about another country’s system and context;
- draw general conclusions about tax law;
- press for or support tax law change;
- facilitate tax law harmonization or coordination among jurisdictions;
- delve into the role of tax in the spread of higher-order values like fairness, equality, transparency, or privacy;
- explain why a country’s tax laws are the way they ...
Tax And Time: On The Use And Misuse Of Legal Imagination,
2022
University of Pittsburgh School of Law
Tax And Time: On The Use And Misuse Of Legal Imagination, Anthony C. Infanti
Book Chapters
In daily life and in tax law, time is taken for granted as something that is ever present but beyond our control. Time moves endlessly and relentlessly forward, constantly slipping from our grasp. But what if life were more like science fiction? What if we could, at will, move through time to alter its course? Or what if we could harness time by turning it into an exchangeable commodity, truly using time as money? In fact, there is no need to open a novel or watch a movie to experience time travel or to see time used as a medium ...
Disabusing The Tax Aid Narrative: What Inter-National Tax Equity Really Means For "Poor" Countries And How To (Re)Frame It,
2022
Dalhousie University Schulich School of Law
Disabusing The Tax Aid Narrative: What Inter-National Tax Equity Really Means For "Poor" Countries And How To (Re)Frame It, Okanga Ogbu Okanga
PhD Dissertations
International tax regimes (e.g., the “double taxation regime”) are created by states with competing tax jurisdiction to coordinate their tax rules and, specifically, to address common efficiency problems like international double taxation. In developing such regimes, states attempt to balance competing tax policy priorities: efficiency, administrability, and equity. This work engages with equity, as a policy norm of international tax (inter-national tax equity). It is my thesis that the framing/articulation of inter-national tax equity suffers from a narrative problem that, perhaps, stems from its apparent conceptual unclarity and multifarious usage. This narrative problem is most evident in the ...
Are Digital Services Taxes Imposed By Other Countries Creditable Under Irc Section 903? Yes. But, What If The Opposite Is True?,
2021
Texas A&M University School of Law
Are Digital Services Taxes Imposed By Other Countries Creditable Under Irc Section 903? Yes. But, What If The Opposite Is True?, Charles Edward Andrew Lincoln Iv
Student Scholarship
This article is divided in the following parts. Part II will discuss and define what Section 903 stands for from a legislative, regulatory, and case perspective. Part III will discuss what digital services taxes are. Part III will define “nexus” and how the concept of “nexus” will relate to Section 903. Part IV concludes by suggesting that digital services taxes do not fall into the traditional statutory paradigm. Ultimately, Section 903 hypothecates that a tax will either be a traditional income tax creditable under Section 901 or tax in the place of that tax. If it does not fall into ...
Tax Incentives And Sub-Saharan Africa,
2021
Pepperdine University
Tax Incentives And Sub-Saharan Africa, Karen B. Brown
Pepperdine Law Review
The OECD’s Base Erosion Profit Shifting (BEPS) project has taken a powerful and welcome look at many of the tax avoidance strategies that proliferate in a world where multinational enterprises are in the business of exploiting gaps in the tax laws of different countries to minimize their ultimate tax bills. The focus on international consensus and prescriptions for reform has not been an unqualified good for the nations in Sub-Saharan Africa, which find themselves in the position of reacting to standards and taking on compliance burdens set without sufficient consideration of their special circumstances. Because the path for the ...
