This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.

In this major new text, Miroslav N.Jovanovic presents an analysis of all the major aspects of economic integration in the European Union. Beginning with an overview of the origins of European integration, he moves on to discuss in detail all the main policy areas. These include: *monetary policy *competition policy *industrial policy *fiscal policy *trade policy *the Common Agricultural Policy *foreign direct investment *regional policy. The volume also includes a discussion of less well-known policy areas, such as social policy, environmental policy and transport policy. Containing an excellent blend of theory and practice and presenting a highly complex issue in an accessible and non-technical way, this text will be an invaluable resource for students of international economics, international business and European studies.

Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.

Proceedings of a seminar organised jointly with the OECD in Toronto in 1994 during the 48th congress of the International Fiscal Association.

Comparative Income Taxation A Structural Analysis Fourth Edition Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries’ tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following: classification of business entities; taxation of corporations and their shareholders; corporate organization and restructuring; taxation of partnerships; residence and source taxation; controlled foreign company rules; restrictions on the deduction of interest; courts dealing with tax matters; and effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.

Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. With a variety of paths to reform proposed throughout, it will prove an invigorating read for tax scholars working on taxation and tax law as well as for tax practitioners and those in fiscal policy seeking ways to improve, or navigate, the current state of affairs in international corporate tax law.

Authoritative resource for defining tax and tax-related terms. With the addition of over 120 completely new definitions and over 100 substantially revised descriptions, this edition contains more than 2,000 tax terms, clearly and concisely defined in English; alphabetical listing of some 400 English terms together with their French, German, Spanish and Dutch equivalents; cross-referenced listing of terms indicating similar, related and contrasting terms; abbreviations and bibliographical references to aid further research; a list of tax-related organizations, with brief descriptions and Internet addresses; accurate descriptions of both traditional and more obscure terms; expanded coverage of terms relating to customs, VAT, capital taxes, transfer pricing and EU tax law terminology; a separate extensive list of tax-related organizations in some 40 countries.