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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 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, Javier Canosa, Aseem Chawla, Pamela A. Fuller, Chandni Javeri, Priyanka Mongia, Jorge Lopez, Marco Ottenwälder, Jan Neugebauer, Eugenio Romita, Guillermo Villaseñor 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, Timur Bondaryev, Olga Ivanova, Felipe Isa Castillo, Avikshit Moral, Apurva Kanvinde 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, John D. Patten 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, Sarah Khaled Alsultan 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, Maame Nyakoa Boateng 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, Sunita Doobay, Daniel Gottfried, Christie Galinski, Gagan Kumar, Jorge Lopez, Elinore Richardson, Eugenio Romita, Guillermo Villaseñor 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, Beckett Cantley, Geoffrey Dietrich 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, Daniel O'Connor 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, Doug Bujakowski, Joan Schmit 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, Paul E. Traynor 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, Dr. Ryan Clements 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, Kim Brooks 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, Anthony C. Infanti 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, Okanga Ogbu Okanga 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?, Charles Edward Andrew Lincoln IV 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, Karen B. Brown 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 ...


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