The Resource Constitutional restraints on corporate tax integration

Constitutional restraints on corporate tax integration

Label
Constitutional restraints on corporate tax integration
Title
Constitutional restraints on corporate tax integration
Creator
Subject
Language
eng
Summary
After an introduction of the subject, part II of this article establishes the basic framework for taxation of cross-border dividends, elaborating briefly on the fundamental concepts of economic double taxation and juridical double taxation and on the various approaches to corporate tax integration. Part III distills the European Court of Justice's (ECJ) complex case law concerning selective relief of economic double taxation and places it into a simple and coherent framework for analysis. This part also offers the authors' critique of the emerging constitutional doctrine governing dividend taxation in Europe. Part IV describes the U.S. case law involving selective relief from economic double taxation at the subnational state level, and thereby lays the groundwork for a comparison of the U.S. and the ECJ jurisprudence involving claims that such relief discriminates against or burdens cross-border trade. Part V provides a comparative analysis of the EU and U.S. case law. Part VI concludes
Citation source
In: Tax law review. - New York. - Vol. 62 (2008),
http://library.link/vocab/creatorName
  • Hellerstein, W
  • Kofler, G.W
  • Mason, R
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • corporate income tax
  • double taxation relief
  • cross-border dividend
  • ECJ case law
  • case law
Label
Constitutional restraints on corporate tax integration
Instantiates
Publication
Label
Constitutional restraints on corporate tax integration
Publication

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      52.37366609999999 4.9336932
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