This case was an adapted version of a tax case heard in U.S. Federal District Court and the US Court of Appeals. The case involved a partnership set-up by a large US corporation with its own subsidiaries as managing partners and foreign partners as outside investors. The formation of the...

This paper considers possible tax implications of the merger between a wholly-owned subsidiary of Domestic Co, Inc. and International Co, Ltd, which took place on November 10, 2008. Even though the merger is structured in a way that it will most likely be respected as a tax-free reorganization...

Nel 1997 un intervento di politica economica regionale, legittimato da una specifica normativa nazionale, cercò di riassorbire l’elevato flusso di consumatori del Friuli Venezia Giulia (FVG) che si recavano in Slovenia per fare rifornimento di carburante. Tale manovra introdusse un meccanismo...

Este documento sugiere la posible existencia de un impuesto implícito a la inversión cuando las deducciones por depreciación no compensan en valor presente el costo de uso del capital. La última reforma tributaria propuso la implementación de un full expensing para eliminar este impuesto...

Some numbers in the political sphere seem to be chosen rather arbitrarily. One example might be the rule set out by the Second Senate of the German Federal Constitutional Court in 1995 that the overall tax load on assets must be limited to 50% of the yield on those assets. This rule was...

From the analysis of advance tax rulings systems conducted throughout this article it would seem highly beneficial to have a harmonized advance tax rulings within the European Union. Whether or not this would be possible is something that we try to discover.

To our knowledge, this paper provides the most comprehensive analysis of firm-level corporate income taxes to date. We use publicly available financial statement information for 11,602 public corporations from 82 countries from 1988 to 2009 to estimate country-level effective tax rates (ETRs)....

The paper takes a tax policy perspective in analysing the approach to tax avoidance in Croatia and expounding its existing shortcomings. It is argued that Croatia is yet to develop a coherent legislative framework suitable for curbing tax avoidance in an equitable, efficient and simple way. One...

Despite an extensive literature on the normative implications of different international tax regimes and an empirical literature addressing individual specific predictions, there exists little evidence encompassing the broad range of effects of taxing corporations' foreign-source income on a...