Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts Gliederung 1. Einleitung 2. Wesentliche Ergebnisse der Untersuchung 3. Zusammenfassung 1....

The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies’ shareholders reside

The world today finds itself in a recession. The global recession was caused by unsustainable borrowing provoked by the self destructive and incoherent “war on terror” in concert with irresponsible bank lending – bad debt. These policies have repercussions beyond the immediate recession:...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

Money laundering has become a phenomenon of financial market regulation. The obligation to identify the ultimate beneficiary, or the beneficiary owner, which need not be entirely synonymous terms, has been the focus for both national authorities and international organizations. However, such...

This paper seeks to expose the origins and impacts of electronic commerce on tax revenues, especially with regard to services and intangibles good transferable via download, making an analysis of the international scenario. Therefore, portrays the rise of the internet and its popularization,...

This document contains four installments of "The Big Picture," a column published in Tax Analysts, International Tax Notes, Volumes 66-68 (2012). The first installment, "Putting Arbitration on the MAP: Thoughts on the New U.N. Model Tax Convention," discusses the addition of mandatory...

FATCA is a US domestic tax policy that requires Foreign Financial Institutions around the world to provide the IRS information regarding their US clients. Recognizing this extraterritorial characteristic and the troubles associated with it, the US Treasury Department developed the...