| Title |
Author |
Type |
Date |
Words |
| SAVING THE PLANET BY CUTTING CORPORATE TAXES: A COMPARATIVE CASE STUDY ANALYSIS. |
Mann, Roberta; Martin, Fiona; Butcher, Bill |
|
Sep 22, 2019 |
19067 |
| Technology - INTERNATIONAL NEWS - France passes tax on tech giants despite US threats. |
|
|
Jul 21, 2019 |
124 |
| The Proper Role of the Tax Department in an MNE's Intercompany Transaction Framework: The tax department typically houses a company's expertise in transfer pricing and is a major consumer of intercompany transaction details, but its responsibility for nonnative intercompany transaction functions can lead to significant risk and incremental income tax exposure. |
Goldberg, Richard |
Cover story |
Jul 1, 2019 |
1604 |
| IS CASH STILL TRAPPED? Recent sweeping federal tax reform lets U.S. companies bring capital back home from overseas to invest domestically. |
Aselta, James; Engel, Russell; Lyons, Bridget; Pannese, Danny |
|
Apr 1, 2019 |
3267 |
| Taxable Nexus: Moving Toward an Economic Approach; Corporate tax professionals might consider OECD approach. |
Visser, Johan; Hidding, Gerbrand |
|
Jan 1, 2019 |
2244 |
| The Impact of GILTI and FDII on the Investment Location Choice of U.S. Multinationals. |
Singh, Kartikeya; Mathur, Aparna |
Report |
May 1, 2018 |
11834 |
| First Look at the Tax Cuts and Jobs Act: Impact of 'GILTI' on International Taxpayers. |
Goldman, Lisa S. |
|
Apr 1, 2018 |
1826 |
| Tax-Efficient Supply Chain in Shadow of Tax Reform: GILTI, FDII, and BEAT: they're not just acronyms - they require reassessing tax consequences of existing supply chain structures. |
Spinowitz, Moshe |
Cover story |
Mar 1, 2018 |
3309 |
| Anatomy of a Multijurisdictional Dispute: Recent tax reform presents additional considerations. |
Williamson, Joel; Kittle, Brian; Osborn, Jason; Horne, John |
|
Mar 1, 2018 |
2610 |
| Territorial Taxation: Choosing Among Imperfect Options. |
Toder, Eric |
Essay |
Dec 1, 2017 |
4545 |
| Practical Questions for Multinationals in an MLI World: MLI moves to implementation with open issues and challenges. |
Corwin, Manal; Eggert, Jesse; Zubler, Monica |
|
Nov 1, 2017 |
4246 |
| The case against income taxation of multinational enterprises. |
Elkins, David |
|
Mar 22, 2017 |
29849 |
| International tax in flux: with more changes coming, what's your game plan? |
Maydew, Jeff; Weber, Julia Skubis |
Cover story |
Mar 1, 2017 |
3344 |
| Economic substance requirements and multinational firm behavior. |
Singh, Kartikeya; Mathur, Aparna |
Report |
Feb 1, 2017 |
9862 |
| TEI comments on section 385 proposed regulations allowing IRS to recharacterize related-party debt to equity. |
|
|
Nov 1, 2016 |
11470 |
| The high cost of tax havens. |
Deneault, Alain |
Reprint |
Jun 22, 2016 |
2677 |
| Corporations' Flight To Low-Tax Countries Angers US Voters. |
|
|
Apr 12, 2016 |
1570 |
| State aid: what it is, and how it may affect multinationals and tax departments; European Commission's actions against member states bear close scrutiny. |
DeNovio, Nicholas J.; Righini, Elisabetta; Gibbs, Nicolle Nonken |
Cover story |
Mar 1, 2016 |
8773 |
| TEI comments on proposed UK tax strategy publication requirement. |
|
|
Mar 1, 2016 |
1761 |
| Country-by-country reporting rules are issued in proposed form. |
Schreiber, Sally P. |
|
Mar 1, 2016 |
549 |
| Profit shifting: effectively connected income and financial statement risks; multinational corporations could be subject to high levels of tax on effectively connected income. |
Kelley, Thomas J.; Koontz, David L.; Kadet, Jeffery M. |
|
Feb 1, 2016 |
3850 |
| Despite BEPS, speed remains top global tax challenge. |
McGerty, Stephen |
|
Jan 1, 2016 |
593 |
| Tax justice in austerity: logics, residues and attachments. |
Bramall, Rebecca |
Report |
Jan 1, 2016 |
10223 |
| BEPS Action 7: preventing the artificial avoidance of permanent establishment status. |
Alajbegu, Jim; Gillum, Shaun; Niculae, Chip; Rudman, Erik |
|
Oct 1, 2015 |
1063 |
| Flee-conomics: American companies take their money and run--for the border. |
Eichelberger, Erika; Gilson, Dave |
|
Mar 1, 2015 |
478 |
| Hockey hands tax dodgers $600m gift: there were 600 million reasons for champagne to be quaffed in the corporate boardrooms of Australia at Christmas, when Treasurer Joe Hockey reneged on his promise to impose tough new tax avoidance rules on multinational companies. |
|
Brief article |
Feb 1, 2015 |
149 |
| Positively Un-American Tax Dodges. |
|
Brief article |
Jul 11, 2014 |
209 |
| Country-by-country reporting by multinationals. |
Nevius, Alistair M. |
|
Jul 1, 2014 |
432 |
| Country-by-country reporting: challenges and considerations. |
Felt, Shawn; Hales, Adam |
|
Jul 1, 2014 |
845 |
| Filing protective claims following redetermination of foreign tax liability. |
Curran, Kevin |
|
Jul 1, 2014 |
936 |
| TEI comments on Canadian budget Consultation on Tax Planning by MNEs (a/k/a BEPS). |
|
|
Jul 1, 2014 |
4466 |
| Cancellation of debt income for debtor subsidiary corporations. |
Islam, Adnan; Camacho, Ramon |
|
Apr 1, 2014 |
2066 |
| Solving a problem with sec. 338 purchase-price allocations. |
Daniel, Russ; Mulders, Maaike; Barnett, Andre J. |
|
Feb 1, 2014 |
1330 |
| Transfer-pricing documentation: possible relief ahead for small multinational companies. |
Clauser, Laura |
|
Feb 1, 2014 |
947 |
| Twilight of the international consensus: how multinationals squandered their tax privileges. |
Sheppard, Lee A. |
|
Jan 1, 2014 |
6537 |
| An Antigua Gambling model for the international tax regime. |
Rosenzweig, Adam H. |
|
Jan 1, 2014 |
8674 |
| TEI comments on OECD transfer pricing documentation and CbC reporting draft: February 22, 2014. |
|
|
Jan 1, 2014 |
14658 |
| International joint audits: is two better than one? |
Chambers, Valrie |
|
Jan 1, 2014 |
1151 |
| Withholding rules for U.S. citizens and resident aliens working for a U.S. employer in a foreign country. |
Gorman, Mary C. |
|
Jan 1, 2014 |
849 |
| Opinion. |
Molloy, Tom |
|
Dec 1, 2013 |
654 |
| Transfer pricing and its effect on financial reporting: multinational companies face high-risk tax accounting. |
McKinley, John; Owsley, John |
|
Oct 1, 2013 |
2711 |
| Local country tax incentives and the foreign tax credit. |
Ward, Travis S. |
|
Sep 1, 2013 |
2189 |
| Foreign branch incorporation: interaction of OFL, branch loss recapture rules. |
Yu, Hui |
|
Jul 1, 2013 |
1115 |
| The EU apportionment formula: insights from a business case. |
Roggeman, Annelies; Verleyen, Isabelle; Van Cauwenberge, Philippe; Coppens, Carine |
|
Apr 1, 2013 |
8159 |
| International tax issues for newly multinational corporations: a due-diligence perspective. |
Weber, Mindy Tyson |
|
Apr 1, 2013 |
1780 |
| The curse of capital flight. |
|
Essay |
Apr 1, 2013 |
632 |
| Rethinking the source of the arm's-length transfer pricing problem. |
Benshalom, Ilan |
|
Jan 1, 2013 |
15129 |
| Tax havens and the money laundering phenomenon. |
Mihu, Stefan |
Report |
Dec 1, 2012 |
4144 |
| Proposed amendments would change apportionment rules. |
Nevius, Alistair M. |
|
Nov 1, 2012 |
573 |
| Transfer pricing strategies and the impact on organizations. |
Tully, Brian |
|
Jul 1, 2012 |
2122 |
| A proposed framework for resolving the transfer pricing problem: allocating the tax base of multinational entities based on real economic indicators of benefit and burden. |
Rectenwald, Glen |
|
Mar 22, 2012 |
10355 |
| Large business and international examination process changes. |
Chambers, Valrie |
|
Jan 1, 2012 |
1224 |
| Considerations in the advance pricing agreement application process: transfer pricing issues for taxpayers. |
Reilly, Robert F. |
|
Sep 1, 2011 |
5040 |
| Re-thinking first principles of transfer pricing rules. |
Burke, John J. |
|
Jan 1, 2011 |
5953 |
| Revitalizing U.S. manufacturing: the role of tax policy. |
Evans, William T.; O'Neil, Brian F.; Stevenson, William J. |
|
Jun 1, 2010 |
2496 |
| Revised bill removes preferential tax for Taiwan-headquartered multinationals. |
|
|
Feb 24, 2010 |
304 |
| IRS's calculation of buy-in payment held unreasonable. |
Beavers, James A. |
|
Feb 1, 2010 |
1901 |
| Taiwan to levy foreign HQs flat 15% business income tax. |
|
Brief article |
Dec 28, 2009 |
204 |
| Overview of income taxes and other taxes on MNCs. |
|
|
Dec 1, 2009 |
640 |
| Headquarters of world-class multinationals eligible for 15% income tax. |
|
Brief article |
Nov 3, 2009 |
248 |
| Are multinationals living in a new world? The U.S. temporary cost sharing regulations. |
Garcia, Michelle; Herr, Thomas; Sanschagrin, Guy |
|
Mar 1, 2009 |
5000 |
| Taxing the financial income of multinational enterprises by employing a hybrid formulary and arm's length allocation method. |
Benshalom, Ilan |
|
Jan 1, 2009 |
20639 |
| 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 |
| TAXATION : TWO SCENARIOS FOR IMPROVED TAX COORDINATION. |
|
|
Dec 12, 2006 |
865 |
| New subpart F lookthrough rules. |
Morrison, Richard |
|
Nov 1, 2006 |
1000 |
| Planning for the currency gap in dispositions of foreign subsidiaries. |
Arndt, Christopher |
|
Apr 1, 2006 |
1217 |
| 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. |
|
|
Sep 1, 2004 |
1300 |
| 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 |
| TEI comments on proposed section 482 services regulations: December 22, 2003. |
|
|
Jan 1, 2004 |
11334 |
| Markers and musings: the proposed section 482 services regulations. |
Lewis, Patricia Gimbel |
|
Nov 1, 2003 |
6913 |
| EU PRESSING CONGRESS TO PASS TAX-REFORM BILL BY YEAR'S END. |
Ramey, Joanna |
|
Oct 13, 2003 |
460 |
| Tax payments by passthrough entities for nonresident owners. |
Beck, Allen M. |
|
Oct 1, 2003 |
524 |
| Firm valuation effects of the expatriation of U.S. corporations to tax-haven countries. |
Cloyd, C. Bryan; Mills, Lillian F.; Weaver, Connie D. |
|
Sep 22, 2003 |
421 |
| California's water's-edge taxation of international businesses: 2003 Update. |
Coffill, Eric J. |
|
Sep 1, 2003 |
4185 |
| Multinational companies avoid paying Danish corporation tax. |
|
Brief Article |
Sep 19, 2002 |
120 |
| 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 |
| 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 |
| The Taxonomist. |
McIntyre, Robert S. |
Brief Article |
Jun 4, 2001 |
874 |
| 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 |
| Global Economy Makes Taxing Harder. |
|
Brief Article |
Mar 1, 2000 |
309 |
| Affirmative use of entity structure in sourcing studies. |
Miller, Louis J. |
|
Sep 1, 1999 |
922 |
| The transfer price is right ... or is it? |
Wrappe, Steven C.; Milani, Ken; Joy, Julie |
|
Jul 1, 1999 |
1998 |
| Tax and accounting aspects of global expansion. |
Winkle, Gary M. |
|
Jun 1, 1999 |
5857 |
| Corporate tax freeloaders. |
Weissman, Robert |
|
Apr 1, 1999 |
809 |
| Collateral consequences of U.S. transfer pricing adjustments. |
|
|
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 |
| An update on foreign taxes. |
Fay, Jack R.; Stryker, Judson P. |
|
Oct 1, 1995 |
3316 |
| Tax court rules on agents as permanent establishments. |
Lubin, Mark L. |
|
Oct 1, 1995 |
1597 |
| 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 |
| "Anti-conduit" regulations issued. |
Lubin, Mark L. |
|
Mar 1, 1995 |
1277 |
| 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 |
| 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 |
| Financing U.S. investments after the Revenue Reconciliation Act of 1993. |
Tuckner, Todd |
|
Feb 1, 1994 |
4955 |
| 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 |
| 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 |
| Consequences of international restructuring. |
Lubin, Mark L. |
|
Apr 1, 1993 |
1422 |
| 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 |
| U.S. taxation of foreign currency transactions: a view from traders' and hedgers' perspectives. |
Tannenbaum, Elliot |
|
Sep 1, 1991 |
1085 |
| Allocation and apportionment of state income taxes to foreign source income: final regulations under Sec. 861. |
Johnsen, Karla M.; Sapperstein, Eric L. |
|
Sep 1, 1991 |
2443 |
| Taxation and the future of offshore insurers. |
Larkins, Ernest R. |
|
Sep 1, 1991 |
2203 |
| Significant unitary developments in California may provide refund opportunities. |
Genetelli, Richard W. |
column |
Aug 1, 1991 |
1080 |
| 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 |
| Amendments to Temp. Regs - allocation of state income taxes against foreign source income. |
Gotlinger, Jeffrey B.; Kraisky, Benjamin P. |
|
Aug 1, 1989 |
1394 |
| 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 |
