The new Tax Cuts and Jobs Act repeals approximately one-third of the foreign tax credit system. (The foreign tax credit generally reduces U.S. tax by the amount of the U.S. taxpayer's foreign income taxes, subject to many requirements.) Essentially, partial repeal will make it much harder to...

Developing countries frequently grant corporate income tax incentives to attract foreign direct investment that would ultimately contribute to their economic growth. To secure the effectiveness of these measures at a cross-border level in the context of jurisdictions that eliminate double...

The 2017 tax law made significant changes to the way the United States taxes multinational corporations on their cross-border income. The new legislation has, however, failed to solve old problems in the international system and also opened the door to new ones.The serious problems created, or...

The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting...

There is an ongoing extensive debate, virtually touching each jurisdiction, regarding the levy of taxes on digital services. Each country, especially the Source countries which have an extensive consumer base of digital services, is grappling with the increasing pressure to tax such services...

The focus of this research is the analysis of Brazil’s international tax policy, understood as the group of justifications and goals of the Country in the drafting of its domestic tax legislation, levied on cross­border transactions, and in the negotiation of international tax treaties. This...

Professor Joseph Sneed a generation ago developed seven macro-criteria for evaluating income tax changes. This paper asks whether those criteria are useful in the general field of international income tax. I conclude that Adequacy, Practicality, Equity, and Free Market Compatibility are...

Given the Republican-controlled House and narrow Democratic majority in the Senate, the Biden Administration has found itself in the perilous situation of needing to raise tax revenue while retaining the support of moderate Democrats. President Biden has proposed raising revenue by bringing the...

This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the three years of treaty negotiations. The 1954...

A report on the International Tax Workshop of the University of New South Wales Taxation, Business, and Investment Law Centre held in August 1988. An important topic of the conference was the proposed Australian controlled foreign company and foreign trust legislation