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The taxation of controlled foreign corporations : an international comparison

Arnold, Brian J. - 1986

Persistent link: https://www.econbiz.de/10000699279

Steuerrechtliche Aspekte der Gründung einer Niederlassung in Großbritannien

Möllering, Jürgen (contributor) - 1991 - 2., völlig überarb. Aufl

Persistent link: https://www.econbiz.de/10000834835

Conduit companies, beneficial ownership, and the test of substantive business activity in claims for relief under double tax treaties

Jain, Saurabh; Prebble, John; Bunting, Kristina - 2014

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

Persistent link: https://www.econbiz.de/10010422265

Qualification of Hybrid Financial Instruments in Tax Treaties

Garcia Prats, Francisco Alfredo - 2013

The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

Persistent link: https://www.econbiz.de/10013082777

Double Tax Relief in Relation to Business Income

Olajide, Omosebi - 2020

As companies seek to expand their operations, globally, a major regulatory bottleneck they encounter is that of Double Taxation. This portends a sort of nauseating feeling for investors who might find the tax burden too heavy to bear. Issues ranging from tax avoidance to outright evasion have...

Persistent link: https://www.econbiz.de/10012842503

Hybrid Entity Double Taxation : A Case Study on the Taxation of Trans-Tasman Limited Partnerships

Elliffe, Craig; Yin, Andrew - 2012

Hybrid entities give rise to international tax problems, and it must be acknowledged, opportunities. Why is this so? This is because, at the heart of the phenomenon, different countries tax systems treat hybrid entities in fundamentally different ways allocating income to different parties. The...

Persistent link: https://www.econbiz.de/10014171963

Apologia for the Double Tax of Corporation Income

Chorvat, Terrence R. - 2004

One of the most controversial aspects of the U.S. income tax system is the double taxation of corporate income. Such income is taxed both when it is earned by the corporation and when it is distributed to the shareholders. Most other kinds of income are taxed only once. It is generally thought...

Persistent link: https://www.econbiz.de/10014117738

Beneficial ownership in tax law and tax treaties

Hernández González-Barreda, Pablo A. - 2020

Kingdom, Canada and the United States; as well as its varied and increasing uses in international tax law. By analysing the …

Persistent link: https://www.econbiz.de/10012136779

Input Tax Credits : What Canada's Federal Court of Appeal Could Have Learned from the U.K. VAT

Pichhadze, Amir - 2013

Recently, in CIBC World Markets Inc. v. R. (“CIBC case”), the Chief Justice of the Tax Court of Canada (“TCC”) was … faced with an issue that was novel to Canada's consumption tax jurisprudence. Can a GST registrant retrospectively change …'s attempt at legal cross-fertilization (or tax transplantation) on the basis that Canada's GST system is “somewhat different …

Persistent link: https://www.econbiz.de/10013083339

Confronting conflicts of qualification in tax treaty law : the principle of common interpretation and the new approach revisited

Pleil, Christoph; Schwibinger, Stefan - In: World tax journal : WTJ 10 (2018) 3, pp. 427-470

Persistent link: https://www.econbiz.de/10012102330

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