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...

The U.S. government has broad discretion to change the transfer pricing regulations as they apply to corporate multinationals. These regulations need changing because they give too much leeway to taxpayers and will continue to serve an important function in the division of international tax...

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...

This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many...

The Internal Revenue Service recently overturned 90 years of United States foreign and tax policy by finalizing and codifying its efforts to report interest income earned at domestic banks for accounts held by nonresident aliens. While the IRS felt its need to collect the data and revenue...

Hong Kong is not a tax haven, but is probably the only international financial centre that is not covered by a Double Tax Agreement (DTA). The relevant DTAs between the People's Republic of China (PRC) and the UK, the PRC and Australia or the PRC and the US do not apply to Hong Kong. This is...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...

In light of the UK Coalition Government's announced intention to reform APD (Air Passenger Duty), this article examines the design flaws making APD an inadequate environmental tax. By identifying the misconceived consequences and environmental inefficiencies of this blunt instrument, the need...