This article springs from two concurrent phenomena. First, U.S. federal deficit spending projections indicate that any feasible deficit reduction plan will require substantial additional revenue. Second, the U.S. system for taxing foreign-source income is so badly flawed that if the United...

The United States approach to taxing foreign-source income is a hybrid worldwide system in form. However, because of deferral of U.S. tax on foreign-source active business income, liberal cross crediting opportunities and other defects, the U.S. system can actually produce a...

This Written Statement presents aspects in China's corporate governance framework, state corporate ownership and control, and the Chinese Communist Party's roles in corporate governance. It was submitted as part of a testimony before the U.S.-China Economic and Security Review Commission,...

Over the past two and a half years, the international tax community has focused on the Base Erosion and Profit Shifting Project (BEPS project) undertaken by the Organisation for Economic Co-operation and Development (OECD) at the behest of the G20. According to the OECD, the resulting 2015...

This is a chapter for the forthcoming book in West Publishing Company's Inside the Minds Series focusing on Financial Services Enforcement and Compliance (published by Aspatore Books). This chapter provides an overview of nature and current state of the markets for the equity side and debt...

The proliferation of different sanctions programs and their accompanying blacklists over the last decade poses a number of issues for those seeking to comply with the Government's controls in good faith. To explore these issues Congress created the Judicial Review Commission on Foreign Asset...

The proliferation of different sanctions programs and their accompanying blacklists over the last decade poses a number of issues for those seeking to comply with the Government's controls in good faith. To explore these issues Congress created the Judicial Review Commission on Foreign Asset...

The proliferation of different sanctions programs and their accompanying blacklists over the last decade poses a number of issues for those seeking to comply with the Government's controls in good faith. To explore these issues Congress created the Judicial Review Commission on Foreign Asset...

This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject...

Analysis of the United States and Greenland Agreement to Improve International Tax Compliance and Implement FATCA, goes through the FATCA agreement from a legal lens. As the world’s largest island, and one that is rapidly being looked to for tourism and mining, the importance of tax...