In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

Recent developments - including greater taxpayer sophistication in structuring and locating international financing arrangements, increased government concerns with the role of debt in sophisticated tax avoidance techniques, and disruption by decisions of the European Court of Justice of member...

This paper examines the circumstances that led to the incorporation of the LIFO method of inventory valuation into the tax law in 1938 and 1939. An understanding of why the LIFO method was adopted after decades of initial opposition by revenue officials may lend perspective to the current policy...

This continuing education program covers significant developments in federal income taxation along with a few other interesting or noteworthy tax topics. It is not intended to provide exhaustive coverage, but it offers a selective treatment of items likely to interest practitioners and advisors...

This manuscript summarizes key provisions of the so-called "Tax Cuts and Jobs Act" affecting United States individuals, small businesses, estates, and trusts. It does not cover changes made to pension and retirement accounts, provisions applicable only to certain industries, rules applicable to...

This article summarizes and provides context to understand the most important developments in federal income taxation for the year 2019. The items discussed primarily consist of the following: (i) significant amendments to the Internal Revenue Code; (ii) important judicial decisions; and (iii)...

This article summarizes and provides context to understand the most important developments in federal income taxation for the year 2018. The items discussed primarily consist of the following: (i) significant amendments to the Internal Revenue Code; (ii) important judicial decisions; and (iii)...

The Committee's planned international tax reform draft (Draft) will undoubtedly suggest some transition from the present deferral system to some other system. As an integral part of that transition, it is expected as well that the Draft will impose taxation on all “accumulated deferred foreign...

In recent years, there is a growing tendency in international taxation to move the right to tax the corporate income of multinational enterprises to the jurisdiction where their customer base is located. One widely discussed proposal applies a sales-only formula to group-wide profits of...

Imputation systems integrate corporate and shareholder personal income taxes to alleviate double taxation of dividend income. In this study, we empirically examine whether a corporate tax rate reduction under an imputation tax system benefits shareholders. Using Taiwan as a setting, our analyses...