The Resource Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?

Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?

Label
Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?
Title
Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?
Creator
Subject
Summary
This article focuses on the international inconsistencies which arise when US tax rules are applied in an international context. The author points out two types of international inconsistencies: policy conflicts and tax system conflicts. Special attention is given to Section 367(a) self- executing gain recognition; the sourcing rule in Section 1.863-7; cross-border securities lending regulations; the dual residence company issue
Citation source
In: Tax Notes International. - Arlington. - Vol. 4 (1992),
http://library.link/vocab/creatorName
Matthews, K
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • source principle of taxation
  • securities lending
  • dual residence
  • stock exchange
Label
Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?
Instantiates
Publication
Label
Inconsistent international tax rules. Legitimate windows of opportunity or loopholes to be closed?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...