The history of ever expanding horizon of service tax law in India has extensive sub-chapters of its own. The levy being unique and unprecedented in the country, the Finance Act, 1994 has made a number of experiments for the levy and collection of service tax from various sectors. Sometimes owing...

The economic downturn has created an investment market in which some tax-advantaged strategies have become favored. To avoid taxable diversification, taxpayers have turned to exchange funds. Through the rules in sections 351, 721, and 368, taxpayers can diversify a single stock position without...

The ability of the Internal Revenue Service (IRS) to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice (“Justice”) stating that the President and...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

On January 1, 2013, the federal estate tax regime in effect from 2001 to 2012 is scheduled to revert to its pre-2001 structure. A 35% rate will soar to a 55% rate. A $5 million exemption will plummet to $1 million. Some deductions and credits enacted in 2001 will disappear while others repealed...

It has become conventional wisdom, based partly on postulated portfolio adjustments by investors in risky assets, (1) to view an income tax as equivalent to a tax levied only on the risk free return to capital and as therefore equivalent to a wealth tax; and (2) to view the difference between an...

Hong Kong is not a tax haven, but is probably the only international financial centre that is not covered by a Double Tax Agreement (DTA). The relevant DTAs between the People's Republic of China (PRC) and the UK, the PRC and Australia or the PRC and the US do not apply to Hong Kong. This is...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...