This companion to International Business and Economics: Law and Policy, Fourth Edition, 2010 covers Articles of Agreement of the International Monetary Fund; General Agreement on Tariffs and Trade; 1979 Subsidies Code; Uruguay Round Agreements; North American Free Trade Agreement; NAFTA Side Agreements; Excerpts from NAFTA Implementation Act; Foreign Sovereign Immunities Act; Excerpts from Cuba Liberty and Democratic Solidarity (Libertad) Act; Foreign Corrupt Practices Act; Excerpts from Trade Law of the United States; Excerpts from Internal Revenue Code; Model Loan Agreement; Model Joint Venture Agreement; and Russian Privatization Regulations.
The question of whether to tax income from wealth has sparked debate since our country's inception. Does taxing capital income ensure the progressivity of our system or merely discourage saving? Would switching our tax code to one that solely taxes consumption be more efficient or only burden middle- and low-income people? And if we were to radically reform the way America taxes its citizens, how could we ensure that vital revenue would not be lost? Some analysts would even argue that, under our present byzantine tax system, we don't really tax capital income at all. In this volume, eminent lawyers and economists analyze the problems associated with taxing capital income and propose policy solutions, which are then challenged by their peers in informed commentary. It may not settle the debate, but policymakers, scholars, and the public will find a wealth of information and ideas to consider. With contributions by Joel Slemrod, Reed Shuldiner, Jane Gravelle, George Zodrow, Alan Auerbach, Eric Toder, Kim Rueben, David Weisbach, Joe Thorndike, Edward Kleinbard, Julie Roin, Paul W. Oosterhuis, Michael Schler, Ed Outslay, George Plesko, and Daniel Halperin
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.