Essays on international taxation : to Sidney I. Roberts, with esteem and affection from the participating authors and the partners of Roberts & Holland
著者
書誌事項
Essays on international taxation : to Sidney I. Roberts, with esteem and affection from the participating authors and the partners of Roberts & Holland
（Series on international taxation, no. 15）
Kluwer Law and Taxation Publishers, 1993
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注記
Includes bibliographical references and index
内容説明・目次
内容説明
This text is written in honour of Sidney I. Roberts, a founding member of the New York law firm of Roberts & Holland and author of many publications on international tax law, on the occasion of his 80th birthday. Over 30 of his professional friends, prominent tax lawyers from a variety of countries, have contributed to the book. Their essays deal with aspects of international taxation either from the perspective of a particular country's tax system or on a more general level.
目次
- Introduction: a tribute to Sidney I. Roberts, William C. Warren
- the taxation of investments in passive foreign investment funds in Australia, Canada, New Zealand and the United States, Brian J. Arnold - the policy of PFIF legislation, Australia, Canada, New Zealand, United States
- the role of the OECD commentaries in the interpretation of tax treaties, Hugh J. Ault - the Vienna convention and tax treaties, fitting the commentaries into the Vienna convention pattern, commentaries as "confirming" the presence of a special meaning, the problem of "ambulatory" commentary
- does the UK give credit for tax on a permanent establishment abroad?, J.F. Avery Jones - the meaning of source in UK tax law, where income arises in UK tax law, tax treaties
- interrelated effects of Canadian and US tax systems over the past twenty-five years, Nathan Boidman - basic similarities, evolving similarities, remaining differences
- preparation of IRS international examiners for treaty-based international issues, Richard L. Doernberg - composition of the treaty materials, treaty issues omitted or inadequately presented, other observations
- a proposal for the creative deconstruction of the federal income tax, Arthur A. Feder - some candidates for deconstruction, what when anything will deconstruction achieve?, who should bell the cat?
- French taxation of real estate investments by foreigners in France, Pierre Fontaneau and Pierre-Marie Fontaneau - possession of a dwelling place in France by an individual, the three per cent tax on the market value of real property owned in France by a legal entity whose corporate headquarters is elsewhere, net wealth tax, income from real property, use of French source income by an individual, corporate tax on income from real property, transfer of the property, taxation of capital gains, taxation of corporate capital gains, estate and gift taxes
- the nature of a partnership, Sanford H. Goldberg - non-tax law, income tax law, estate and gift taxation, treaty interpretation
- transfer pricing - US and Japanese views, Joseph H. Guttentag and Toshio Miyatake - development of United States transfer pricing rules, the US/Japan tax treaty, development of Japanese transfer pricing rules, definition of revenues, provisions governing donations, the denial of acts or accounting of a family company, Japanese transfer pricing legislation, frictions between the US and Japan relating to differences in transfer pricing rules and their administrations, US/Japan history of regulation conflicts, competent authority, competent authority procedural issues, preconfirmation and advance pricing agreements, why US/Japan transfer pricing rules. (Part conte
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