On January 1, 1994, Canada, the United States and Mexico formed the North American Free Trade Agreement (NAFTA) to promote their economic interests by lowering barriers to international trade and investment. A concern exists that national tax differences harm or inhibit cross-border investment...

The focus of this research is the analysis of Brazil’s international tax policy, understood as the group of justifications and goals of the Country in the drafting of its domestic tax legislation, levied on cross­border transactions, and in the negotiation of international tax treaties. This...

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...

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...

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...

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...

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...

This work undertakes a comprehensive analysis of the US state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may...