INTERNATIONAL

Cross-Border Outsourcing: U.S. International Tax Pitfalls, Pratfalls, And Opportunities

I. INTRODUCTION Broadly defined, “outsourcing” occurs when a business contracts with a third party to provide goods or perform services that traditionally have been provided or performed in-house.[1] Faced with increasing global competition, businesses have come to look to outsourcing as a means of gaining a comparative advantage over their competitors.[2] Outsourcing is thought to benefit a business by allowing...

Taxation as a Global Socio-Legal Phenomenon

Allison Christians [*] Steven A. Dean Diane Ring Adam Rosenzweig This essay makes a proposal that may not be controversial among those with a particular interest in international law, but may be less accepted among those primarily interested in tax law: that international social and institutional structures shape, and are shaped by, historical and contemporary domestic policy decisions. As a result, to incorporate...

Developing an International Tax Policy Strategy for NAFTA Countries

On January 1, 1994, Canada, the United States, and Mexico formed the North American Free Trade Agreement to promote their economic interests by lowering barriers to international trade and investment. A concern exists that national tax differences harm or inhibit cross-border investment. Yet NAFTA is almost silent regarding tax measures. For the most part, the tax treatment of cross-border trade and investment flows...

United Nations Code of Conduct on Cooperation in Combating International Tax Evasion

Abstract: Stopping international tax evasion and abusive tax avoidance is an exceedingly difficult task unless countries act together in a cooperative manner. The League of Nations, which undertook in the 1920s to foster the goal of taxing income once and only once, recognized from the start that cooperative efforts were essential for success. A first step in getting international cooperation is establishing international...
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