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International Tax, Margriet Lukkien, Christie Galinski, David Dingfa Liu, Aseem Chawla, Eugenio Romita, Guillermo Villsenor, Jorge Lopez, Star Q. Lopez 2021 Southern Methodist University

International Tax, Margriet Lukkien, Christie Galinski, David Dingfa Liu, Aseem Chawla, Eugenio Romita, Guillermo Villsenor, Jorge Lopez, Star Q. Lopez

The Year in Review

No abstract provided.


Repurposing Pillar One Into An Incremental Global Tax For Sustainability: Some Blue Sky Thinking In The Midst Of Global Crisis, Jinyan Li, Sophie Chatel 2021 Osgoode Hall Law School of York University

Repurposing Pillar One Into An Incremental Global Tax For Sustainability: Some Blue Sky Thinking In The Midst Of Global Crisis, Jinyan Li, Sophie Chatel

Articles & Book Chapters

In this article, the authors make a case for repurposing the OECD Pillar One from a mechanism for reallocating taxing rights to a global tax on the largest and most profitable MNEs’ market-based profits. Such global tax would have the hybrid features of a net-basis corporate income tax and a turnover-basis digital services tax through a conversion formula that ensures a low-rate DST on sales can replicate a higher rate CIT on a country’s share of the profit determined using under the formulary allocation method. More importantly, the authors instill a common purpose of the international tax consensus – to ...


Tax Planning For Foreign Expansion By U.S. Petroleum Companies, Martin Van Brauman 2021 United States Internal Revenue Service

Tax Planning For Foreign Expansion By U.S. Petroleum Companies, Martin Van Brauman

Journal of Natural Resources & Environmental Law

No abstract provided.


Federal Tax Considerations In Foreign Oil And Gas Operations By Domestic Oil Companies, Martin M. Van Braumen 2021 United States Internal Revenue Service

Federal Tax Considerations In Foreign Oil And Gas Operations By Domestic Oil Companies, Martin M. Van Braumen

Journal of Natural Resources & Environmental Law

No abstract provided.


Federalizing Tax Justice, Reuven Avi-Yonah, Orli Avi-Yonah, Nir Fishbien, Hayian Xu 2021 University of Michigan Law School

Federalizing Tax Justice, Reuven Avi-Yonah, Orli Avi-Yonah, Nir Fishbien, Hayian Xu

Articles

The United States is the only large federal country that does not have an explicit way to reduce the economic disparities among more and less developed regions. In Germany, for example, federal revenues are distributed by a formula that takes into account the relative level of wealth of each state (the so-called Finanzausgleich, or fiscal equalization). Similar mechanisms are found in Australia, Canada, India, and other large federal countries. The United States, on the other hand, has no such explicit redistribution. Each state is generally considered equal and sovereign, and the federal government does not distribute revenues to equalize the ...


Summaries From The 2020 36th Annual Tei-Sjsu High Tech Tax Institute, Charlene Kliatchko, Jane Lei CPA, Hanna Shatanionak CPA, Liubov (Luba) Shilkova, Xiaoyue Tan 2021 San Jose State University

Summaries From The 2020 36th Annual Tei-Sjsu High Tech Tax Institute, Charlene Kliatchko, Jane Lei Cpa, Hanna Shatanionak Cpa, Liubov (Luba) Shilkova, Xiaoyue Tan

The Contemporary Tax Journal

No abstract provided.


Table Of Contents, Seattle University Law Review 2021 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


A Major Simplification Of The Oecd’S Pillar 1 Proposal, Michael J. Graetz 2021 Columbia Law School

A Major Simplification Of The Oecd’S Pillar 1 Proposal, Michael J. Graetz

Faculty Scholarship

In this report, Graetz suggests major modifications to the OECD’s pillar 1 blueprint proposal to create a new taxing right for multinational digital income and some product sales that would greatly simplify the proposal. The modifications rely on readily available existing financial information and would achieve certainty in the application of pillar 1, while adhering to its fundamental structure and policies.


Enough Is As Good As A Feast, Noah C. Chauvin 2020 Seattle University School of Law

Enough Is As Good As A Feast, Noah C. Chauvin

Seattle University Law Review

Ipse Dixit, the podcast on legal scholarship, provides a valuable service to the legal community and particularly to the legal academy. The podcast’s hosts skillfully interview guests about their legal and law-related scholarship, helping those guests communicate their ideas clearly and concisely. In this review essay, I argue that Ipse Dixit has made a major contribution to legal scholarship by demonstrating in its interview episodes that law review articles are neither the only nor the best way of communicating scholarly ideas. This contribution should be considered “scholarship,” because one of the primary goals of scholarship is to communicate new ...


Table Of Contents, Seattle University Law Review 2020 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


International Tax: Tax Treaties, Kim Brooks 2020 Schulich School of Law, Dalhousie University

International Tax: Tax Treaties, Kim Brooks

OER Texts

This compendium of materials is designed to support the study of tax treaties around the world.


A Positive Dialectic: Beps And The United States, Reuven S. Avi-Yonah 2020 University of Michigan Law School

A Positive Dialectic: Beps And The United States, Reuven S. Avi-Yonah

Articles

This essay addresses the interaction between the changes in the international tax regime identified by Mason and U.S. international tax policy. Specifically, I will argue that contrary to the general view, the United States actively implemented the Organisation for Economic Co-Operation and Development (OECD)/G20 Base Erosion and Profit Shifting (BEPS) recommendations through the Tax Cuts and Jobs Act of 2017 (TCJA). Moreover, the changes of the TCJA influenced the current OECD effort of BEPS 2.0. Thus, the current state of affairs can be characterized as a constructive dialogue: The OECD moves (BEPS 1), the United States responds ...


Front Matter (Letter From The Editor, Masthead, Etc.), 2020 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


The Tax Treatment Of Haircuts In Financial Reorganizations, Aurelio GURREA-MARTINEZ, Vincent OOI 2020 Singapore Management University

The Tax Treatment Of Haircuts In Financial Reorganizations, Aurelio Gurrea-Martinez, Vincent Ooi

Research Collection School Of Law

Over the past few years, Singapore has implemented various ambitious insolvency reforms aimed at making the country an international hub for debt restructuring. This article argues that while Singapore has put in place one of the most sophisticated restructuring frameworks in the world, some tax reforms might be useful to maximise the potential of this new restructuring framework. Namely, it will be pointed out that the tax treatment of debt forgiveness granted by creditors in corporate reorganisation (‘haircuts’) should be reviewed. Under the current legislation, these haircuts may be treated as taxable income. As a result, financially distressed debtors may ...


South Dakota V. Wayfair: An Ill-Conceived Blow To The Free Flow Of Interstate Commerce, Revel Shinn Atkinson 2020 Brooklyn Law School

South Dakota V. Wayfair: An Ill-Conceived Blow To The Free Flow Of Interstate Commerce, Revel Shinn Atkinson

Brooklyn Journal of Corporate, Financial & Commercial Law

For more than a century, brick-and-mortar retailers have been losing local customers—first with the rise of mail-order houses and then more acutely with the rapid growth of online retail. As a result, states have noticed a significant loss in sales tax revenue. While an equivalent amount of tax is typically still owed to the state in the form of a use tax, which is to be remitted to the state by the customer, because these taxes are not automatically collected at the time of the sale, customers have overwhelmingly elected not to pay them. In an effort to recover ...


Racialized Tax Inequity: Wealth, Racism, And The U.S. System Of Taxation, Palma Joy Strand, Nicholas A. Mirkay 2020 Creighton University

Racialized Tax Inequity: Wealth, Racism, And The U.S. System Of Taxation, Palma Joy Strand, Nicholas A. Mirkay

Northwestern Journal of Law & Social Policy

This Article describes the connection between wealth inequality and the increasing structural racism in the U.S. tax system since the 1980s. A long-term sociological view (the why) reveals the historical racialization of wealth and a shift in the tax system overall beginning around 1980 to protect and exacerbate wealth inequality, which has been fueled by racial animus and anxiety. A critical tax view (the how) highlights a shift over the same time period at both federal and state levels from taxes on wealth, to taxes on income, and then to taxes on consumption—from greater to less progressivity. Both ...


Digital Taxation - A Virtual Reality, Rachana Khandelwal 2020 San Jose State University

Digital Taxation - A Virtual Reality, Rachana Khandelwal

The Contemporary Tax Journal

No abstract provided.


Summaries From The 2019 35th Annual Tei-Sjsu High Tech Tax Institute, Hanna Shatanionak CPA, Liubov (Luba) Shilkova, Xiaoyue (Tina) Tan 2020 San Jose State University

Summaries From The 2019 35th Annual Tei-Sjsu High Tech Tax Institute, Hanna Shatanionak Cpa, Liubov (Luba) Shilkova, Xiaoyue (Tina) Tan

The Contemporary Tax Journal

No abstract provided.


More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis 2020 Mercer University School of Law

More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis

Mercer Law Review

In December of 2017, the United States (U.S.) enacted tax reform commonly known as the “Tax Cuts and Jobs Act” (TCJA), which was initially thought to “establish[] a territorial tax system for multinational companies.” Over time, however, tax professionals began to understand that the TCJA layered a territorial tax system that exempted foreign earnings from the U.S. income tax (exemption tax system) on top of a residence-based worldwide tax system that used a foreign tax credit (FTC) to protect against juridical double taxation (worldwide tax system). Furthermore, the U.S. exemption tax system is severely limited by the ...


How Hard Can This Be? The Dearth Of U.S. Tax Treaties With Latin America, Patricia A. Brown 2020 University of Miami School of Law

How Hard Can This Be? The Dearth Of U.S. Tax Treaties With Latin America, Patricia A. Brown

University of Miami Law Review

The United States has fewer tax treaties with countries in Latin America and the Caribbean than the United Kingdom, France, Germany, Spain and even China have with such countries. After first describing ways in which tax treaties reduce barriers to cross-border trade and investment, this Article considers in turn various possible explanations for this situation. It examines, and rejects, the hypothesis that Latin American countries are reluctant to enter into tax treaties in general. It then considers, and rejects, the possibility that Latin American countries are opposed to in-creased trade and investment from the United States in particular. It then ...


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