Virtual permanence: consideration of the virtual office in international income tax treaties with the United States

Article Abstract:

International income tax treaties are inefficient in taxing virtual offices because they have been drafted to contemplate physically permanent establishments conducting traditional commercial activities. Virtual offices can be deemed permanent establishments for international tax purposes only by forced and tenuous analogy. A better solution is to create new rules and tests to define and tax businesses as virtually permanent establishments.

Interpretation and construction, Tax treaties, Electronic commerce, E-commerce, Virtual corporations

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Revisiting U.S. anti-deferral rules

Article Abstract:

US anti-deferral tax rules are a major tax issues in an era of multinationals, controlled foreign corporations, and passive foreign investment companies. Critics say the rules inhibit US companies' ability to compete globally. Repealing deferral or instituting a territorial system are possible solutions but, even without a repeal, the check-the-box entity classification rules will provide tax simplification in this area of the law.

Foreign corporations, Tax shelters, Foreign source income taxation, Controlled foreign corporations

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