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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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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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Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules
Bulletin for International Taxation, 2014An assumption of the OECD Base Erosion and Profit Shifting initiative is that a holistic approach should be adopted. This article suggests that the reshaping of controlled foreign company rules should be coordinated with changes to corporate tax residence and anti-hybrid arrangement rules.
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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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The transformative power of foreign direct investment in Ukraine’s market for corporate control
Journal of Contemporary Central and Eastern Europe, 2018This article analyses the marketization of corporate control in Ukraine. To date, sceptical forecasts have identified Ukraine’s blurred EU accession perspective and the enduring volatility of its s...
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Limits of State Control of Foreign Corporations
University of Pennsylvania Law Review and American Law Register, 1909openaire +1 more source