Similar Search Results

Do Chinese Income Taxes Qualify for the U.S. Foreign Tax Credit?

Pomp, Richard; Gelatt, Timothy; Surrey, Stanley - 2021

is a serious concern for foreign countries. For example, in China authorities have expressed a willingness to pursue a … levied on the income of a foreign corporation from which it receives dividends.This article looks at two taxes that China … stay. The JVITL taxes joint ventures operating in China on their world-wide income derived from production, business, and …

Persistent link: https://www.econbiz.de/10013212630

Judging the New International Tax Regime : Testimony Before the U.S. Senate Committee on Finance

Kysar, Rebecca M. - 2018

The 2017 tax law made significant changes to the way the United States taxes multinational corporations on their cross-border income. The new legislation has, however, failed to solve old problems in the international system and also opened the door to new ones.The serious problems created, or...

Persistent link: https://www.econbiz.de/10012920203

U.S. International Tax Policy and Corporate America

Hanna, Christopher H.; Wilson, Cody A. - 2023

Given the Republican-controlled House and narrow Democratic majority in the Senate, the Biden Administration has found itself in the perilous situation of needing to raise tax revenue while retaining the support of moderate Democrats. President Biden has proposed raising revenue by bringing the...

Persistent link: https://www.econbiz.de/10014343747

The Influence of the 1954 Japan-United States Income Tax Treaty on the Development of Japan’s International Tax Policy

Masui, Yoshihiro - 2012

This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the three years of treaty negotiations. The 1954...

Persistent link: https://www.econbiz.de/10013110164

How Reform-Friendly Are U.S. Tax Treaties?

Shaheen, Fadi - 2017

This paper — prepared for a symposium held at Brooklyn Law School on October 23, 2015 on Reconsidering the Tax Treaty — addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform proposal is treaty compatible obviates the...

Persistent link: https://www.econbiz.de/10012970073

Permanent Establishment in the United States -- A View Through Article V of the U.S.-Canada Tax Treaty

Tittle, Martin B. - 2014

The last time someone wrote comprehensively about permanent establishment in the United States, the catchwords of the day were Mayaguez, Watergate, and Squeaky Fromme. At that time, there were only nine U.S. cases and thirteen revenue rulings addressing permanent establishment. Perhaps not...

Persistent link: https://www.econbiz.de/10014139775

The End of Taxation without End : A New Tax Regime for U.S. Expatriates

Schneider, Bernard - 2012

One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

Persistent link: https://www.econbiz.de/10013096911

Investing with One Hand Tied Behind Your Back – An Australian Perspective on United States Tax Rules for Non-Resident Citizens

Alpert, Karen - 2018

The United States is unique in taxing non-resident citizens under the same rules as residents. For Australian citizens and residents who are also US taxpayers, the impact of this is much greater than the generally minimal amount of US tax due each year. The US grants citizenship broadly and...

Persistent link: https://www.econbiz.de/10012930860

Charitable Giving, Tax Expenditures, and Direct Spending in the United States and the European Union

Faulhaber, Lilian V. - 2014

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

Persistent link: https://www.econbiz.de/10013063896

US taxation of international income : blueprint for reform

Hufbauer, Gary Clyde - 1992

Persistent link: https://www.econbiz.de/10000855795

1
2
3
4
5
6
7
8
9
10
Next
Last