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The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the...
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One of the important changes of the 1986 tax reform for U.S. multinationals is related to the allocation of interest expense. Prior to 1986, U.S. companies allocated domestic interest expense to the income of foreign affiliates on a non-consolidated basis according to the distribution of gross...
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To answer the question posed in our title, we first review how corporate income taxes are shared in federal countries, EU efforts to harmonize corporate taxes, and previous experience with attempts at ‘global' taxation. In all cases, the main lessons that emerge are that it takes much time and...
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This paper discusses issues related to the taxation of financial intermediation in Hong Kong in the context of Hong Kong's position as a major regional financial centre. It first provides some background analysis as to the definition of financial intermediation and identification of the...
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