Financing infrastructure investment by taxing foreign corporations
Article Abstract:
Pres Clinton's idea of raising the income tax on US-based subsidiaries of foreign corporations and earmarking the proceeds for infrastructure enhancements is unlikely to succeed. The administrative system currently in place for taxing such corporations is already cumbersome. Further, the notion of raising taxes disproportionately on foreign firms poses diplomatic problems. Indeed, the existing system of taxing foreign firms needs to be reformed.
Publication Name: Regulation
Subject: Law
ISSN: 0147-0590
Year: 1993
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Contribution to capital or contribution to confusion?
Article Abstract:
The guidance provided by the IRS in Technical Advice Memorandum (TAM) 9822005 may have greater impact on ancillary issues than on the primary issue regarding cancellation of debt income. Application of common law, interaction between IRC subsections 108(e)(6) and (e)(10)(A), and related party transactions are dealt with deceptively. The TAM is of limited direct benefit, but should not be disregarded due to the treatment of ancillary issues.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1999
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Cross-border tax issues of collective investment institutions and the Italian approach
Article Abstract:
Issues pertaining to taxation of collective investment institutions (CII) are discussed alongwith Italian domestic legislation to recognize these institutions.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2005
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