This paper discusses foreign shipowners who transport cargo between domestic ports, using ships that are engaged primarily in the international import/export trade. It compares the taxation of such foreign shipowners with the taxation of coastal shipowners. Areas of comparison include business...

When taxpayers discover that their transactions have unwanted tax consequences, they routinely rely on the unwind doctrine found in Internal Revenue Service Revenue Rulings 80-58. Nowadays, “unwinding” has become a “common if not ubiquitous feature of tax practice.” This article finds...

This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

There are several fundamental problems with the judicial concept of income, that is, the concept of income that the courts employ for tax purposes. First, the judicial concept sees income as a flow, rather than as a gain. Secondly, as a consequence, it taxes some apparent flows that do not...

There are several fundamental problems with the judicial concept of income, that is, the concept of income that the courts employ for tax purposes. First, the judicial concept sees income as a flow, rather than as a gain. Secondly, as a consequence, it taxes some apparent flows that do not...

In this third in a series of four articles, the authors examine the German Real Estate Investment Trust (REIT) regime. Previous articles dealt with REITs in the United States and the United Kingdom. A subsequent and final article concludes with a comparison of the three regimes. This article...

In this first of a series of four articles, the authors consider real estate investment trust (REIT) regimes in general, and, then, focus on US REITs. In subsequent articles the authors deal with UK and German REITs, before concluding with a comparison of the three regimes. The United States was...

A collated bibliography of Cedric Sandford's works. The categories are research books and monographs; other research books and monographs; general texts; contributions to books; evidence and memoranda for Parliamentary Committees; and more important articles since 1965

From a tax policy point of view, one of the demerits of a foreign investment fund regime is that it causes the law to treat forms of investment that are similar in economic purpose and effect as if they were different. In particular, it I likely to distinguish between direct investments by...

This is a chapter of a book on foreign investment fund regimes. Most features of foreign investment fund regimes fit reasonably neatly into the analytical framework of definition, boundaries, scope, exceptions, and calculation of income, topics that are dealt with in other chapters of the book....