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Articles
1-99 out of 99 article(s)
| Title |
Author |
Type |
Date |
Words |
| Special Purpose Companies Holding Investments In China May Not Be Protected By Tax Treaties. |
Cao, Fuli |
|
Nov 12, 2009 |
924 |
| Danish Tax Planning Opportunities: Holding Companies, Investment Companies And Limited Territoriality Taxation. |
Ottosen, Arne |
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Nov 12, 2009 |
1517 |
| Cost Of Expatriate Secondments Could Increase From Tax Policy Shift. |
|
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Nov 6, 2009 |
508 |
| Planning For The Entry Into Force Of Treaty Changes Affecting Hybrid Entities On January 1, 2010. |
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Oct 8, 2009 |
2955 |
| New Developments On Transfer Pricing. |
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Sep 11, 2009 |
589 |
| Effective Removal Of Cyprus From Spanish Tax "Blacklist". |
|
Brief article |
Feb 26, 2009 |
300 |
| Taxing the financial income of multinational enterprises by employing a hybrid formulary and arm's length allocation method. |
Benshalom, Ilan |
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Jan 1, 2009 |
20639 |
| Global Tax Management For Emerging Trans National Corporations. |
|
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May 27, 2008 |
1181 |
| Empathy Imperative Of Transfer-Pricing Norms. |
|
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Mar 4, 2008 |
850 |
| Tax liability of a U.S. multinational corporation operating a foreign business entity. |
Yang, James G.S.; Jeffers, Agatha E. |
|
Mar 1, 2008 |
7807 |
| Multinationals and VAT compliance in the United Kingdom. |
Meghjee, Kassim |
|
May 1, 2007 |
4095 |
| Dividend policy inside the multinational firm. |
Desai, Mihir A.; Foley, C. Fritz; Hines, James R., Jr. |
Report |
Mar 22, 2007 |
11282 |
| Belize International Business Corporations (IBC) Yield Asset Protection And Tax Advantages; Easy And Fast To Establish. |
Curshen, Jonathan |
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Mar 21, 2007 |
3153 |
| Cross-Border Liquidity For U.S. Issuers. |
|
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Feb 9, 2007 |
3406 |
| New subpart F lookthrough rules. |
Morrison, Richard |
|
Nov 1, 2006 |
1000 |
| Paragraph 247(2)(b) Demystified. |
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May 20, 2006 |
3478 |
| Taxing multinationals. |
Fine, Howard |
Brief article |
May 8, 2006 |
135 |
| Planning for the currency gap in dispositions of foreign subsidiaries. |
Arndt, Christopher |
|
Apr 1, 2006 |
1217 |
| Does Your Foreign, International or Interstate Business Have a Hidden and Costly State Tax Liability? |
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Mar 15, 2006 |
622 |
| Transfer Pricing for Intangible Development: Alternatives to Cost-Sharing. |
Norton, D. Clarke; Burns, Paul B. |
|
Mar 8, 2006 |
3049 |
| Not all transfer-pricing rules are created equal. |
Nobre, Lionel Bonner |
|
May 1, 2005 |
956 |
| Forms of overseas operations. |
Shum, Michael G. |
|
Apr 1, 2005 |
5524 |
| Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas. |
Shum, Michael G. |
|
Mar 1, 2005 |
3983 |
| Estimating marginal tax rates when entering foreign markets. |
Larkins, Ernest R. |
|
Oct 1, 2004 |
4144 |
| Estimating marginal tax rates when entering foreign markets. |
Larkins, Ernest R. |
|
Sep 1, 2004 |
3897 |
| The changing face of VAT. |
Walsh, Chris |
|
Sep 1, 2004 |
3996 |
| Statement before Senate Foreign Relations Committee on Dutch and Barbados treaties: September 24, 2004. |
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|
Sep 1, 2004 |
1300 |
| Daily Tax Update: Ways And Means Committee Approves $145 Billion FSC/ETI Bill. |
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Jun 16, 2004 |
662 |
| Transfer pricing getting more scrutiny: a survey by Ernst & Young finds that government authorities are putting more attention and more resources to examining--and even auditing--transfer-pricing transactions. |
Kirwan, Karen |
|
May 1, 2004 |
1878 |
| Nexus, The Threshold Requirement For State Taxation Of Multi-State Businesses. |
|
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Apr 16, 2004 |
5491 |
| Daily Tax Update - Foreign Partners of Multinational Service Partnerships Confirmed Subject to U.S. Taxation. |
|
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Jan 30, 2004 |
976 |
| TEI comments on proposed section 482 services regulations: December 22, 2003. |
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Jan 1, 2004 |
11334 |
| Markers and musings: the proposed section 482 services regulations. |
Lewis, Patricia Gimbel |
|
Nov 1, 2003 |
6913 |
| Tax payments by passthrough entities for nonresident owners. |
Beck, Allen M. |
|
Oct 1, 2003 |
524 |
| California's water's-edge taxation of international businesses: 2003 Update. |
Coffill, Eric J. |
|
Sep 1, 2003 |
4185 |
| New Dual Consolidated Loss Rules in Germany. |
|
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Aug 7, 2002 |
1526 |
| Tax Reforms in Cyprus. |
|
Statistical Data Included |
Jul 12, 2002 |
1172 |
| Potential opportunity to increase FTC use. |
Smith, Annette B. |
|
Jul 1, 2002 |
447 |
| U.S. export rules in question; dispute over international trade agreements continues. |
Fiore, Nicholas J. |
|
May 1, 2002 |
574 |
| Nigeria: Blessed are not the tax dodgers; multinational oil companies wanting to pay less tax have merged their operations, but the Nigerian government says no, not here. (For the Record). |
Lokongo, Antoine |
Brief Article |
May 1, 2002 |
730 |
| International Dialogue on Taxation. |
|
Brief Article |
Mar 28, 2002 |
279 |
| TRANSFER PRICING: A Truly Global Concern. |
Yamada, Mito |
|
Nov 1, 2001 |
2005 |
| Tax Study: U.S. Firms At Disadvantage. |
|
Brief Article |
Oct 1, 2001 |
357 |
| WTO Rules Against U.S. Export Tax Law. |
Stone, Ben |
Brief Article |
Oct 1, 2001 |
970 |
| Treasury's long-awaited Subpart F study breaks no new ground, touts ending deferral. |
Garrett-Nelson, LaBrenda |
|
Jan 1, 2001 |
5678 |
| The Appraisal Profession at the Cross Roads. |
MacCrate, James R.; Peterson, David L. |
|
Jul 1, 2000 |
3824 |
| "Check-the-box" prop., regs. - extraordinary transactions could cause extraordinary results. |
Zent, Brenda |
|
Jun 1, 2000 |
1068 |
| Affirmative use of entity structure in sourcing studies. |
Miller, Louis J. |
|
Sep 1, 1999 |
922 |
| Tax and accounting aspects of global expansion. |
Winkle, Gary M. |
|
Jun 1, 1999 |
5857 |
| Collateral consequences of U.S. transfer pricing adjustments. |
|
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Mar 1, 1999 |
2490 |
| IRS targets multinationals. |
Sheard, Tony J. |
|
May 1, 1998 |
2466 |
| Mapping out a tax plan. |
Dennis, Anita |
|
Sep 1, 1997 |
1379 |
| Public economics program meeting. |
|
|
Jun 22, 1997 |
1029 |
| Check-the-box: European options, U.S. and European consequences. |
Zink, William J. |
|
Feb 1, 1997 |
644 |
| Complex rules burden outbound transfers of tangibles and intangibles. |
McLeighton, Steven W. |
|
Feb 1, 1997 |
6472 |
| Final regs. clarify cost sharing of R & D expenditures. |
Picciano, Kenneth C. |
|
Jan 1, 1997 |
7206 |
| Sourcing losses. |
Young, Sophie |
Brief Article |
Jan 1, 1997 |
503 |
| Entering foreign markets - one step at a time. |
Benson, David M. |
|
Oct 1, 1996 |
2876 |
| IRS issues proposed regulations on allocation and apportionment of research and experimental expenditures. |
Goodman, Mark E. |
|
Sep 1, 1996 |
1133 |
| Dual resident company regulations: the mirror legislation provision. |
Young, Sophie |
Brief Article |
Aug 1, 1996 |
468 |
| Proposed section 863(b) regulations: sourcing of income from export sales. |
|
|
Jul 1, 1996 |
2789 |
| MNCs should start addressing sec. 404A issues. |
Windsor, Josh G. |
|
Jul 1, 1996 |
831 |
| Repeal of section 956A: excess passive assets. |
|
|
Jan 1, 1996 |
590 |
| Proposed revision of Revenue Procedure 65-17: adjustments required after a section 482 allocation. |
|
|
Jan 1, 1996 |
4920 |
| U.K. taxation: a quiet revolution. |
Dent, Christopher H. |
|
Jul 1, 1995 |
1205 |
| Unitary combined reporting for state income tax purposes - new developments. |
Dennen, Sylvia |
|
Jul 1, 1995 |
652 |
| Pending tax treaties and protocols. |
|
|
Mar 1, 1995 |
745 |
| OECD Draft Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. |
|
|
Jan 1, 1995 |
2181 |
| Pending U.S. tax treaties. |
|
|
Nov 1, 1994 |
676 |
| International taxation. |
Hines, James, Jr. |
|
Sep 22, 1994 |
4055 |
| Rent allocated to foreign corporation subject to gross income tax. |
Burge, Marianne |
Brief Article |
Jul 1, 1994 |
441 |
| Court ruling on unitary tax saves California $1.3 billion. |
Crabtree, Penni |
|
Jun 27, 1994 |
603 |
| Update on U.S. classification of U.K. LLCs. |
Blum, Richard A. |
|
May 1, 1994 |
488 |
| Unraveling the mysteries of Sec. 304 in international tax planning. |
Jacobsohn, R. Bruce |
|
Mar 1, 1994 |
5551 |
| Canadian release increases fears of U.S.-Canadian transfer pricing disputes. |
Bennett, Mary C. |
|
Mar 1, 1994 |
3045 |
| U.S. tax relief for foreign partners. |
Mezzo, Louis J. |
|
Feb 1, 1994 |
1386 |
| Tax Court rules on interest income and expense netting for determining deduction allocated between parent and DISC. |
Zink, William J. |
|
Feb 1, 1994 |
771 |
| Financing U.S. investments after the Revenue Reconciliation Act of 1993. |
Tuckner, Todd |
|
Feb 1, 1994 |
4955 |
| Battle rages over state taxation of foreign-based multinationals. |
Berger, Robin |
|
Aug 30, 1993 |
818 |
| New U.S.-Netherlands treaty may adversely affect Netherlands holding company structures. |
Serota, Jack N. |
|
Jul 1, 1993 |
1435 |
| Investing in Eastern Europe through hybrid entities can ease U.S. FTC problems. |
Eigenbrode, Richard |
|
Jul 1, 1993 |
2056 |
| Clinton's tax plan: royalty and R&E provisions for multinationals. |
|
|
May 1, 1993 |
493 |
| Letter to President Clinton on Barclays case. |
|
|
May 1, 1993 |
837 |
| Over there. |
Fiore, Nicholas J. |
|
Apr 1, 1993 |
698 |
| Group claims Clinton will deter foreign investment. |
|
|
Mar 24, 1993 |
376 |
| An overview of corporate tax issues involving the European Community. |
Todd, Heidi I. |
|
Jan 1, 1993 |
1728 |
| Resolution of international tax disputes in and out of court: section 482 from the trial lawyer's view. |
Oates, Mark A. |
|
Jan 1, 1993 |
8021 |
| U.S. Model Income Tax Treaty. |
|
|
Jan 1, 1993 |
4727 |
| AICPA criticizes dual consolidated loss rules as unnecessarily restrictive. |
|
|
Sep 1, 1992 |
231 |
| Foreign tax reform bill. |
|
Brief Article |
Aug 1, 1992 |
484 |
| IRS loses Sundstrand - again. |
|
|
May 1, 1992 |
474 |
| Proposed section 367 regulations. |
|
|
Mar 1, 1992 |
4210 |
| 6038A guidance issued. |
Biebl, Andrew R. |
|
Feb 1, 1992 |
378 |
| To the water's edge: repeal of the worldwide unitary tax. |
Kleeschulte, Chuck |
Industry Overview |
Nov 1, 1991 |
2444 |
| Bring U.S. tax law into the 1990s. |
Mattson, Robert N. |
|
May 1, 1991 |
1119 |
| Creditability of Canada's proposed large corporations tax in foreign jurisdictions. |
|
|
Nov 1, 1989 |
490 |
| Why it is critical to reexamine global tax strategies. |
O'Leary, Patrick J. |
|
Sep 1, 1989 |
2871 |
| The Section 482 White Paper - a Canadian perspective. |
Boidman, Nathan |
|
Mar 22, 1989 |
13895 |
| Allocating interest and other expenses under Section 864(e). |
Richey, Keith S. |
|
Mar 22, 1989 |
9537 |
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