This article investigates the taxation of investments in the Asia-Pacific region. The authors' analysis is based on the methodology of Devereux and Griffith (1999 and 2003) for determining effective average tax rates. This approach allows the authors to account for important domestic and...

This contribution deals with the question whether - from the perspective of cross-border neutrality - tax reductions for personal circumstances should be applied only by the country of residence, or whether they should also be granted by the source country, and, if so, how such tax reductions...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

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,...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...

The United States tax classification of a “foundation” created under the laws of a foreign jurisdiction is a complicated matter. “Foundations” are not creatures of common law, but are derived from civil law. The United States follows common law and this body of jurisprudence is more...

Canada is one of many countries where taxpayer rights are becoming an increasingly common topic of discourse among policymakers, practitioners, and the public. Especially in light of recent developments regarding the global expansion of taxpayer information exchange, the role of taxpayer privacy...

In both Australia and the U.S., the tax anti-avoidance law has evolved to include two common doctrinal components. One component requires evidence of taxpayers' tax avoidance purpose. The other component protects transactions clearly contemplated by the tax statute against charges of tax...

This paper comprises a transcript of the oral addresses and discussion at a colloquium that compared the general anti-avoidance rule of income tax law with the civil law doctrine of Rechtsmissbrauch (abuse of law) and similar doctrines in eight jurisdictions: Germany, Croatia, New Zealand,...

This article, which is based on the inaugral address given at the IBFD Tax Lecture Series in Beijing, China, examines the basic foundations and nature of income tax law before going on to offer a unifying theory of taxation law. Income tax law is notoriously complex for a range of reasons. One...