Results 221 to 230 of about 309,277 (264)
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The Evolution of Controlled Foreign Corporation Rules and Beyond
Bulletin for International Taxation, 2019This article traces the evolution of controlled foreign corporation (CFC) rules, including their compatibility with treaty provisions. It argues that CFC rules would be preferable to the Inclusive Framework proposal on the OECD/G20 Base Erosion and Profit Shifting Project (Pillar Two) for a uniform minimum tax on all CFC income.
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Bulletin for International Taxation
In controlled foreign corporation rules, the adoption of the term “participation” both in the definition of control and in the ratable income inclusion rule may cause double taxation. The author considers these rules, and suggests a narrow interpretation of the term “participation” used in the ratable income inclusion rule as “entitlement to profits”.
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In controlled foreign corporation rules, the adoption of the term “participation” both in the definition of control and in the ratable income inclusion rule may cause double taxation. The author considers these rules, and suggests a narrow interpretation of the term “participation” used in the ratable income inclusion rule as “entitlement to profits”.
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Two Paths for Developing Controlled Foreign Corporation Rules in China
Bulletin for International Taxation, 2016In this article, the author discusses the different international tax policy considerations for outbound investments and inbound investments in China. In particular, the author argues that the current rough and broad-based controlled foreign corporation rules, together with their light enforcement, are best for China.
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New Controlled Foreign Corporation Rules and the Alternative Investment Fund Managers Directive
Finance and Capital Markets (formerly Derivatives & Financial Instruments), 2015The author considers the interplay between the new controlled foreign corporation rules in Spain and the EU Alternative Investment Fund Managers Directive, and the light that can be shed on this issue by case law of the European Court of Justice.
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Controlled Foreign Corporation Rules – A Proposal for the Caribbean
Intertax, 2004exaly +2 more sources
Corporate Control, Foreign Ownership Regulations and Technology Transfer*
Economic Record, 2009Multinationals are often required to form joint ventures (JVs) with local firms when entering the host country market. Explicitly taking corporate control into account, we explore the relationship between technology transfer and foreign ownership regulation in the presence of technology spillovers from JVs to local firms.
JOTA ISHIKAWA +2 more
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Journal of International Accounting, Auditing and Taxation, 1994
Abstract The Internal Revenue Service (IRS) is concerned that foreign-controlled domestic corporations (FCDCs) are incurring less U.S. tax liabilities than their U.S. -controlled counterparts. This study examines gross profit margins of FCDCs and U.S.-controlled domestic corporations (USCDCs) to determine whether FCDCs are manipulating income through
Terry L. Crain, Randal H. Stitts
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Abstract The Internal Revenue Service (IRS) is concerned that foreign-controlled domestic corporations (FCDCs) are incurring less U.S. tax liabilities than their U.S. -controlled counterparts. This study examines gross profit margins of FCDCs and U.S.-controlled domestic corporations (USCDCs) to determine whether FCDCs are manipulating income through
Terry L. Crain, Randal H. Stitts
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Foreign Policy Export Controls and American Multinational Corporations
California Management Review, 1986The increasing utilization of foreign policy export controls by the U. S. Government has generated considerable conflicts with American multinational corporations. The exercise of such controls against the Soviet Union, Iran, Nicaragua, Libya, and other countries entails loss of sales for many American firms and also threatens important MNC objectives ...
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