Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

By taking the Great Wall of China as an analogy for China's treaty policy, the author considers key aspects of China's treaty network and its implications, and whether or not this constitutes a “Great Fiscal Wall of China.”Cited with the permission of IBFD

Arguments for eliminating the double taxation of dividends apply only to dividends paid by corporations to individuals. The double (and multiple) taxation of dividends paid by one firm to another - intercorporate dividends - was explicitly included in the 1930s as part of a package of tax and...

Firms that lobbied for the tax holiday for repatriations provided under the American Jobs Creations Act of 2004 were the largest beneficiaries of the provision. They repatriated an average of over $4 billion under the Jobs Act. Although firms that lobbied for the tax holiday repatriated large...

Hufbauer and colleagues critically evaluate the Organization for Economic Cooperation and Development's ambitious multipart project titled Base Erosion and Profit Shifting (BEPS), which contains 15 "Actions" to prevent multinational corporations (MNCs) from escaping their "fair share" of the tax...

This paper examines the treaty practices currently adopted by several countries in Asia to see how those treaty practices might need to change if the countries were inclined to follow the OECD's recommendations. In other words, this paper asks how robust are the countries' current treaty...

A report on the International Tax Workshop of the University of New South Wales Taxation, Business, and Investment Law Centre held in August 1988. An important topic of the conference was the proposed Australian controlled foreign company and foreign trust legislation

A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...