En matière de fiscalité, l’Europe s’est construite avec pour seuls buts l’élimination des doubles impositions et des discriminations, l’idée d’une harmonisation qui faisait encore débat dans les années `70 n’étant désormais plus à l’ordre du jour. La mise en concurrence...

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...

NOTE: This paper is an unfinished work of William D. Andrews, who was the Eli Goldston Professor of Law at Harvard Law School and a premier tax scholar of his generation. This substantial but not fully completed manuscript was found among his papers after his death on May 20, 2017. It examines...

This paper investigates the effect at the bank and industry level of a 1996 tax law change allowing commercial banks to elect S-corporation status. By the end of 2007, roughly one in three commercial banks had either opted for or converted to the S-corporation form of organization. Our study...

One important question facing shareholder-employees of small, closely-held C corporations is how to pay themselves for working in and/or running their corporations. Traditionally, C corporation shareholder-employees have been advised to pay themselves compensation instead of dividends, because...

In 1985 New Zealand had a tax system that taxed corporate profits twice, first in the hands of the company and secondly in the hands of the shareholder, known as the “classical system”. The paper suggests how dividends from capital sources ought to be treated if this double taxation is to...

This study examines the relationship between dividend yield and stock returns for firms in the United Arab Emirates, where there are no taxes on dividend incomes and capital gains. Following methods of Black and Scholes (1974) and Litzenberger and Ramaswamy (1979), we find that yield...

Albania journey towards EU membership is governed by the Stabilization and Association Agreement (SAA), signed on June 12th, 2006. This article rises above Albania's obligations for the alignment of its tax legislation with EU standards and acquis, clearly defined in Title VI of the SAA. Unlike...