This article explores how local taxing authorities might apply the beneficial ownership concept in an OECD-based tax treaty to dividends paid on equity that is referenced in a cross-border total return equity swap. The article examines the OECD Commentary, relevant case law, recent guidelines...

Capital markets appreciate stability. It means that companies reporting smooth earnings patterns tend to be priced relatively high. However, the empirical issue is whether such valuation premiums for earnings smoothness are justified. We examine the relationships between past five-year earnings...