Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

The standard analysis of the optimal international tax policy of a small country typically assumes that the country either imports or exports capital, but does not do both. This paper considers the situation in which a small country both exports and imports capital and can alter its tax on one...

Recent theoretical work has argued that a small open economy should use residence-based but not source-based taxes on capital income. Given the ease with which residents can evade domestic taxes on foreign earnings from capital, however, a residence-based tax may not be administratively...

This study examines the extent to which investor-level taxes affect the pricing and pre-tax returns of securities. Specifically, we investigate whether the pre-tax yield on outstanding conventional preferred stock (CPS) decreased after the 2003 Jobs and Growth Tax Relief Reconciliation Act...

The standard analysis of the optimal international tax policy of a small country typically assumes that the country either imports or exports capital, but does not do both. This paper considers the situation in which a small country both exports and imports capital and can alter its tax on one...

In recent years U.S. companies have been able to use new tax planning strategies to reduce the foreign taxes they pay on their foreign earnings. Since the companies usually can defer the residual U.S. tax on these earnings, one effect of the reduction in foreign taxes is to increase a...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

Does Australia’s international claim to tax trust-level capital gains apply the jurisdictional rules of trust taxation based on source, or those of capital gains taxation based on ‘taxable Australian property’, or a hybrid of the two? The article sets out to answer the question by...