Book contents
- Frontmatter
- Contents
- Abbreviations
- 1 Introduction
- 2 International taxation: policy and law
- 3 Some shortcomings of the tax treaty system
- 4 History of tax treaties and the permanent establishment concept
- 5 The role of the OECD Model Tax Treaty and Commentary
- 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary
- 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report
- 8 Intra-bank interest under the 2008 Report
- 9 Business restructuring involving permanent establishments and the OECD transfer pricing methods
- 10 New Article 7 of the OECD Model and Commentary
- 11 Unitary taxation
- 12 Conclusion
- Bibliography
- Index
- References
Bibliography
Published online by Cambridge University Press: 07 September 2011
Book contents
- Frontmatter
- Contents
- Abbreviations
- 1 Introduction
- 2 International taxation: policy and law
- 3 Some shortcomings of the tax treaty system
- 4 History of tax treaties and the permanent establishment concept
- 5 The role of the OECD Model Tax Treaty and Commentary
- 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary
- 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report
- 8 Intra-bank interest under the 2008 Report
- 9 Business restructuring involving permanent establishments and the OECD transfer pricing methods
- 10 New Article 7 of the OECD Model and Commentary
- 11 Unitary taxation
- 12 Conclusion
- Bibliography
- Index
- References
Summary
A summary is not available for this content so a preview has been provided. Please use the Get access link above for information on how to access this content.
- Type
- Chapter
- Information
- International Taxation of Permanent EstablishmentsPrinciples and Policy, pp. 436 - 453Publisher: Cambridge University PressPrint publication year: 2011
References
???The Coordination of Tax Policy: The EU Experience???2000 World Tax ConferenceTampa Bay, FloridaCanadian Tax Foundation 2000 1 1Google Scholar
???Interstate and International Double Taxation???Lectures on TaxationNew YorkCCH 1932 101Google Scholar
‘International and Interstate Aspects of Double Taxation’ 1929 22 National Tax Association Proceedings193Google Scholar
The Delineation of Apportionment of an EU Consolidated Tax Base for Multi-Jurisdictional Corporate Income Taxation: A Review of Issues and OptionsEuropean Commission Taxation Papers 2006Google Scholar
Federal Income Tax Project, International Aspects of United States Income Taxation II, Proposals on United States Income Tax TreatiesPhiladelphiaThe American Law Institute 1992Google Scholar
Tax Discrimination Against Aliens, Non-Residents, and Foreign Activities: Canada, Australia, New Zealand, the United Kingdom and the United StatesTorontoCanadian Tax Foundation 1991Google Scholar
???The Canadian General Anti-Avoidance Rule???Tax Avoidance and the Rule of LawAmsterdamIBFD 1997 221Google Scholar
‘Summary of Proceedings of an Invitational Seminar on the Attribution of Profits to Permanent Establishments’ 2001 49 Canadian Tax Journal525Google Scholar
‘The Allocation of Income and Expenses Among Countries: Report on the Invitational Conference on Transfer Pricing’ 1993 10 Australian Tax Forum545Google Scholar
‘Summary of the Proceedings of an Invitational Seminar on Tax Treaties in the 21st Century’ 2002 50 Canadian Tax Journal65Google Scholar
‘Summary of Proceedings of an Invitational Seminar on the Taxation of Business Profits Under Tax Treaties’ 2003 57 Bulletin for International Fiscal Documentation187Google Scholar
‘Corporate Integration, Tax Treaties and the Division of the International Tax Base: Principles and Practice’ 1992 47 Tax Law Review565Google Scholar
???The Role of the OECD Commentaries in the Interpretation of Tax Treaties???Essays on International TaxationDeventerKluwer 1993 61Google Scholar
???Taxing International Income: An Analysis of the US System and its Economic Premises???Taxation in the Global EconomyChicagoUniversity of Chicago Press 1990 11Google Scholar
‘The David R. Tillinghast Lecture: Are Tax Treaties Necessary?’ 1999 53 Tax Law Review1Google Scholar
‘Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State’ 2000 113 Harvard Law Review1573CrossRefGoogle Scholar
‘The Rise and Fall of Arm's Length: A Study in the Evolution of US International Taxation’ 1995 15 Virginia Tax Review89Google Scholar
‘The Structure of International Taxation: A Proposal for Simplification’ 1996 74 Texas Law Review1301Google Scholar
???International Law and Domestic Law???Public International LawMelbourneOxford 1997 119Google Scholar
A New Capital Adequacy Framework, Consultative Paper Issued by the Basel Committee on Banking SupervisionBank of International SettlementsBasel 1999Google Scholar
2010
2009 www.bis.org/bcbs/history.pdf
Consultative Document: Strengthening the Resilience of the Banking SectorBank for International Settlements 2009Google Scholar
2009
1998
International Convergence of Capital Measurement and Capital Standards: A Revised Framework, Comprehensive VersionBank for International Settlements 2006Google Scholar
The Treatment and Taxation of Foreign Investment under International LawManchester University Press 2000Google Scholar
BIAC Comments on OECD Revised Commentary on Article 7 of the OECD Model Tax ConventionBusiness and Industry Advisory Committee of the OECD 2007Google Scholar
2008
2001
2006
‘Shaping a New International Tax Order’ 1988 42 Bulletin for International Fiscal Documentation292Google Scholar
The Taxation of International Income Flows: Issues and ApproachesWellingtonVictoria University Press 1987Google Scholar
2002
‘The Interjurisdictional Allocation of Income and the Unitary Taxation Debate’ 1986 34 Canadian Tax Journal1377Google Scholar
???Source- vs. Residence-Based Taxation in the European Union: The Wrong Question????Taxing Capital Income in the European UnionOxfordOxford University Press 2000 78Google Scholar
‘The Compliance Cost of Taxing Foreign-Source Income: Its Magnitude, Determinants, and Policy Implications’ 1995 2 International Tax and Public Finance37CrossRefGoogle Scholar
1999
???Here or There? The Source and Residence Principles of International Taxation???Taxation to 2000 and BeyondTorontoCanadian Tax Foundation 1992 303Google Scholar
2001
‘How the IRS Applies the Intercompany Pricing Rules of Section 482: A Comparative Survey’ 1980 454 Journal of Taxation308Google Scholar
???Water's Edge Versus Worldwide Unitary Combination???The State Corporate Income Tax, Issues in Worldwide Unitary CombinationStanfordHoover Institution Press 1984Google Scholar
???The Impact of Transfer Pricing on Intrafirm Trade???International Taxation and Multinational ActivityChicagoUniversity of Chicago Press 2001 173CrossRefGoogle Scholar
Reforming Corporate Taxation in a Global Economy: A Proposal to Adopt Formulary ApportionmentWashingtonThe Brookings Institution 2007Google Scholar
2002
???The Nature of the Firm (1937)???The Nature of the FirmNew YorkOxford University Press 1991 18Google Scholar
???The Nature of the Firm: Influence???The Nature of the FirmNew YorkOxford University Press 1991 61Google Scholar
‘Federal Formulary Apportionment as an Alternative to Arm's Length Pricing: From the Frying Pan to the Fire?’ 1993 59 Tax Notes1103Google Scholar
Communication from the Commission to the Council, the European Parliament and the European Economic and Social CommitteeImplementing the Community Lisbon Programme: Progress to date and next steps towards a Common Consolidated Corporate Tax BaseBrussels 2006Google Scholar
Report of the Committee of Independent Experts on Company TaxationCommission of the European CommunitiesBrussels 1992Google Scholar
Towards an Internal Market without Tax Obstacles: A Strategy for Providing Companies with a Consolidated Corporate Tax Base for their EU-Wide ActivitiesCommission to the Council, the European Parliament and the Social CommitteeBrussels 2001Google Scholar
‘A Rose by Any Other Name: Smelling the Flowers at the OECD's (Last) Resort’ 1995 10 Tax Notes InternationalGoogle Scholar
2008
‘The Taxation of Domestic and Foreign Banking’ 2001 79 Journal of Public Economics429CrossRefGoogle Scholar
‘A New International Tax Order – Responding to the Challenge’ 1991 45 Bulletin for International Fiscal Documentation465Google Scholar
‘Do We Still Need Tax Treaties?’ 2000 54 Bulletin for International Fiscal Documentation619Google Scholar
Report on Double Taxation Submitted to the Financial Committee by Professors Bruins, Einaudi, Seligman and Sir Josiah StampLeague of NationsGeneva 1923Google Scholar
???Taxes, Transfer Pricing, and the Multinational Enterprise???Oxford Handbook of International BusinessOxfordOxford University Press 2009 591Google Scholar
Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North AmericaTorontoUniversity of Toronto Press 1998CrossRefGoogle Scholar
???Designing and Implementing a Target-Effective General Anti-Avoidance Rule???Tax Avoidance in Canada After Canada Trustco and MathewTorontoIrwin Law 2007 221Google Scholar
‘Source Taxation and the OECD Project on the Attribution of Profits to Permanent Establishments’ 2005 37 Tax Notes International525Google Scholar
2007 www.ey.com/Publication/vwLUAssets/Precision_under_pressure/$FILE/Precision_under_pressure.pdf
‘Tax Administration Goes Global: Complexity, Risks and Opportunities’ 2007 45 Tax Notes International Magazine813Google Scholar
‘Transfer Pricing 1999 Global Survey: Practices, Perceptions, and Trends for 2000 and Beyond’ 1999 19 Tax Notes International1907Google Scholar
2009 http://ey.mobi/Publication/vwLUAssets/2009_EY_Global_transfer_pricing_survey/$FILE/Ernst%20&%20Young%202009%20Global%20transfer%20pricing%20survey.pdf
2004
Consultation Document: The Application of International Accounting Standards (IAS) in 2005 and the Implications for the Introduction of a Consolidated Tax Base for Companies’ EU-Wide ActivitiesEuropean Commission 2003Google Scholar
2006
2005
2005
London and Mexico Model Tax Conventions: Commentary and TextLeague of NationsGeneva 1946Google Scholar
Report to the Council on the Work of the First Session of the CommitteeLeague of NationsGeneva 1929Google Scholar
Report to the Council on the Work of the Second Session of the CommitteeLeague of NationsGeneva 1930Google Scholar
Report to the Council on the Work of the Third Session of the CommitteeLeague of NationsGeneva 1931Google Scholar
Report to the Council on the Fourth Session of the CommitteeLeague of NationsGeneva 1933Google Scholar
Report to the Council on the Fifth Session of the CommitteeLeague of NationsGeneva 1935Google Scholar
Report to the Council on the Seventh Session of the CommitteeLeague of NationsGeneva 1937Google Scholar
Report to the Council on the Work of the Eighth Session of the CommitteeLeague of NationsGeneva 1938Google Scholar
Report to the Council on the Work of the Ninth Session of the CommitteeLeague of NationsGeneva 1939Google Scholar
Communiqué, ‘Meeting of Finance Ministers and Central Bank Governors’BusanRepublic of Korea 2010Google Scholar
2008
‘Transfer Pricing in Emerging Markets – An Indian Perspective 2006 28 International Tax Review13Google Scholar
2006
‘The David R. Tillinghast Lecture: Taxing International Income: Inadequate Principles, Outdated Concepts, and Unsatisfactory Policies’ 2001 54 Tax Law Review261Google Scholar
‘The “Original Intent” of US International Taxation’ 1997 46 Duke Law Journal1021CrossRefGoogle Scholar
‘Structuring an Exemption System for Foreign Income of US Corporations’ 2001 54 National Tax Journal771CrossRefGoogle Scholar
‘The Future of Source-Based Taxation of the Income of Multinational Enterprises’ 1993 79 Cornell Law Review18Google Scholar
2008 www.ifs.org.uk/mirrleesreview/press_docs/international.pdf
‘Key Issues and Options in International Taxation: Taxation in an Interdependent World’ 2001 55 Bulletin for International Fiscal Documentation546Google Scholar
‘Rethinking the Financial Network’Paper presented at the Financial Student AssociationAmsterdam 2009Google Scholar
???Arm's Length ??? How Long????International and Comparative Taxation: Essays in Honour of Klaus VogelThe HagueKluwer Law 2002 29Google Scholar
Corporate/Shareholder Income Taxation and Allocating Taxing Rights between CountriesAmsterdamIBFD 1996Google Scholar
‘Should Depreciation Be Marked Up in a Transactional Net Margin Method Context for Service Providers?’ 2008 15 International Transfer Pricing Journal27Google Scholar
‘Federal Income Taxation of Multinationals: Replacement of Separate Accounting with Formulary Apportionment’ 1993 60 Tax Notes1131Google Scholar
‘The Case for Formulary Apportionment’ 2005 3 International Transfer Pricing Journal103Google Scholar
‘The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States’ 2004 11 International Tax and Public Finance199CrossRefGoogle Scholar
‘The Interpretation of Double Taxation Agreements – The Australian Experience’ 2003 57 Bulletin for International Fiscal Documentation320Google Scholar
International Taxation and Multinational ActivityChicagoUniversity of Chicago Press 2001CrossRefGoogle Scholar
2005
2009
2010
‘Misunderstood Derivatives: The Causes of Informational Failure and the Promise of Regulatory Incrementalism’ 1993 102 Yale Law Journal1457CrossRefGoogle Scholar
US Taxation of International IncomeWashingtonInstitute for International Economics 1992Google Scholar
‘Comments on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments’ 2001 23 Tax Notes International477Google Scholar
2006
The Attribution of Profits to Permanent EstablishmentsRotterdamCahiers de droit fiscal international 2006Google Scholar
Legal Problems of International Economic RelationsSt Paul, MinnesotaWest Publishing Company 1986Google Scholar
The Impact of State Sovereignty on Global Trade and International TaxationThe HagueKluwer Law 1999Google Scholar
Report of Investigations of Enron Corporation and Related Entities Regarding Federal Tax and Compensation Issues, and Policy RecommendationsUS CongressWashington 2003Google Scholar
‘Some Thoughts on the Use of Later OECD Commentaries After Prevost Car’ 2009 54 Tax Notes International667Google Scholar
‘Fairness and the Taxation of International Income’ 1998 29 Law and Policy in International Business145Google Scholar
‘Attribution of Profits to Branches of International Banks: The OECD Discussion Drafts’ 2005 20 Banking and Finance Law Review319Google Scholar
‘The Aftermath of the Case: Australia's Tax Treaty Override’ 2005 59 Bulletin for International Fiscal Documentation236Google Scholar
‘The Tax Treaty Implications of the Foreign Bank Tax Measures’ 2002 17 Banking and Finance Law Review181Google Scholar
OECD Discussion Draft on the Attribution of Profits to Permanent Establishments, Representations of KPMG's Worldwide Banking Tax PracticeKPMG 2001 www.oecd.org/dataoecd/48/16/2673215.pdfGoogle Scholar
‘The Role of the OECD Commentary in Tax Treaty Interpretation’ 2008 23 Australian Tax Forum95Google Scholar
‘A Modified Fractional Apportionment Proposal for Transfer Pricing’ 1992 54 Tax Notes719Google Scholar
‘Transfer Pricing and the End of International Taxation’ 1999 19 Tax Notes International1201Google Scholar
‘Global Profit Split: An Evolutionary Approach to International Income Allocation’ 2002 50 Canadian Tax Journal823Google Scholar
‘Slicing the Digital Pie with a Traditional Knife – Effectiveness of the Arm's Length Principle in the Age of E-Commerce’ 2001 24 Tax Notes International775Google Scholar
‘The Relationship between Domestic Anti-Avoidance Legislation and Tax Treaties’ 1997 45 Canadian Tax Journal891Google Scholar
‘International Tax Issues in a Rapidly Changing World’ 2001 55 Bulletin for International Fiscal Documentation2Google Scholar
‘Territorial Taxation: Why Some US Multinationals May Be Less than Enthusiastic About the Idea (and Some Ideas They Really Dislike)’ 2006 59 Southern Methodist Law Review751Google Scholar
???Multilateral Tax Treaty Versus Bilateral Treaty Network???Multilateral Tax TreatiesLondonKluwer Law International 1998 83Google Scholar
2006
???Is Europe One Market? A Transfer Pricing Economic Analysis of Pan-European Comparables Sets???, Deloitte White Paper (2004), p. 1: reproduced in European CommissionEU Joint Transfer Pricing ForumBrussels 2004 Taxud/C1/LDH/WBGoogle Scholar
???Transfer Pricing and Latin American Integration???Taxation and Latin American IntegrationWashingtonInter-American Development Bank and the David Rockefeller Center for Latin American Studies, Harvard University 2008Google Scholar
‘Colloquium on NAFTA and Tradition: Formulary Taxation in the North American Free Trade Zone’ 1994 49 New York University Tax Review691Google Scholar
‘Territorial vs Worldwide Taxation: Which Is Better for the US?’ 2007 8 Florida Tax Review283Google Scholar
1993
‘The Design of Tax Rules for the North American Free Trade Alliance’ 1994 49 Tax Law Review769Google Scholar
???The Use of Combined Reporting by Nation States???The Taxation of Business Profits under Tax TreatiesTorontoCTF 2003Google Scholar
‘Opinion: Using NAFTA to Introduce Formulary Apportionment’ 1993 6 Tax Notes International851Google Scholar
Globalization, Tax Rules and National Sovereignty’ 2001 55 Bulletin for International Fiscal Documentation328Google Scholar
‘International Aspects of Tax Policy for the 21st Century’ 1990 8 The American Journal of Tax Policy167Google Scholar
State Income Taxation of Multistate Corporations in the United States of AmericaNew YorkUnited Nations 1974Google Scholar
Tax Assignment and Subnational Fiscal Autonomy’ 2000 54 Bulletin for International Fiscal Documentation626Google Scholar
‘US Federal Use of Formula Apportionment to Tax Income from Intangibles’ 1997 14 Tax Notes International859Google Scholar
???Defining a Unitary Business: An Economist's View???The State Corporate Income Tax, Issues in Worldwide Unitary CombinationStanfordHoover Institution Press 1984Google Scholar
‘Replacing Separate Entity Accounting and the Arm's Length Principle with Formulary Apportionment’ 2002 56 Bulletin for International Fiscal Documentation586Google Scholar
???Deciding Whether the European Union Should Adopt Formula Apportionment of Company Income???Taxing Capital Income in the European UnionOxfordOxford University Press 2000 243Google Scholar
‘Globalization of the Corporate Income Tax: The Role of Allocation’ 1999 56 Finanzarchiv389Google Scholar
???Will Corporate Income Tax Wither????2000 World Tax Conference ReportTorontoCanadian Tax Foundation 2000Google Scholar
2006
2007
‘Sovereignty, Entitlement, and Cooperation in International Taxation’ 2001 26 Brooklyn Journal of International Law1335Google Scholar
United States Taxation of Foreign Investment Income: Issues and ArgumentsCambridge, MassachusettsThe Law School of Harvard University 1969Google Scholar
???Inter-Nation Equity???Modern Fiscal IssuesTorontoUniversity of Toronto Press 1972 63Google Scholar
???Transfer Pricing and Income Shifting in Integrated Economies???Taxing Capital Income in the European UnionOxfordOxford University Press 2000 214Google Scholar
‘The US National Interest in International Tax Policy’ 2001 54 New York University Tax Review337Google Scholar
Discussion Draft on the Attribution of Profits to Permanent EstablishmentsParisOECD 2001Google Scholar
Discussion Draft on the Attribution of Profits to Permanent Establishments: Part I General ConsiderationsParisOECD 2004Google Scholar
Discussion Draft on the Attribution of Profits to Permanent Establishments: Part II (Banks)ParisOECD 2003Google Scholar
Discussion Draft on the Attribution of Profits to Permanent Establishments: Part III (Global Trading of Financial Instruments)ParisOECD 2005Google Scholar
Discussion Draft on the Attribution of Profits to Permanent Establishments: Part IV (Insurance)ParisOECD 2005Google Scholar
Revised Discussion Draft of a New Article 7 of the OECD Model Tax ConventionParisOECD 2009Google Scholar
Tax Aspects of Transfer Pricing Within Multinational Enterprises: The United States Proposed Regulations: A Report by the Committee on Fiscal Affairs on the Proposed Regulations under Section 482 IRCParisOECD 1993Google Scholar
Transfer Pricing Aspects of Business Restructurings: Discussion Draft for Public CommentParisOECD 2009Google Scholar
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Discussion Draft of Part IParisOECD 1994Google Scholar
Transfer Pricing Guidelines for Multinational Enterprises and Tax AdministrationsParisOECD 1995Google Scholar
Transfer Pricing Guidelines for Multinational Enterprises and Tax AdministrationsParisOECD 2009Google Scholar
Transfer Pricing Guidelines for Multinational Enterprises and Tax AdministrationsParisOECD 2010Google Scholar
The Elimination of Double TaxationParisOrganisation for European Economic Co-operation 1958Google Scholar
The Elimination of Double Taxation, Second Report of the Fiscal CommitteeParisOrganisation for European Economic Co-operation 1959Google Scholar
The Elimination of Double Taxation, Third Report of the Fiscal CommitteeParisOrganisation for European Economic Co-operation 1960Google Scholar
The Elimination of Double Taxation, Fourth Report of the Fiscal CommitteeParisOrganisation for European Co-operation 1967Google Scholar
‘Transfer Pricing: A Critical Issue for Multinational Companies’ 2006 42 Tax Notes International407Google Scholar
‘The Unitary Method and the Less Developed Countries: Preliminary Thoughts’ 1987 International Business Law Journal 45Google Scholar
‘Globalization and the US International Tax Rules’ (Paper presented at the IRS/George Washington University 15th Annual Institute on Current Issues in International TaxationWashington 2002Google Scholar
‘Emerging Issues in Tax Reform: The Perspective of an International Bureaucrat’ 1997 15 Tax Notes International2035Google Scholar
‘Should the Arm's Length Principle Retire?’ 2005 3 International Transfer Pricing Journal99Google Scholar
‘A Comprehensive Look at the Berry Ratio in Transfer Pricing’ 2005 40 Tax Notes International759Google Scholar
‘Transfer Pricing Method Selection in the United States and Canada’ 2004 5 Corporate Business Taxation Monthly7Google Scholar
‘The Freedom of a State to Legislate in Fiscal Matters under General International Law’ 1987 41 Bulletin for International Fiscal Documentation14Google Scholar
???Deemed Expenses of a Permanent Establishment under Article 7 of the OECD Model???International Studies in Taxation: Law and EconomicsLondonKluwer 1999 285Google Scholar
‘A History of Controlled Foreign Corporations and the Foreign Tax Credit’ 2007 27 Statistics of Income Bulletin (US Internal Revenue Service)129Google Scholar
‘Pan-European Comparables Searches – Analysing the Search Criteria’ 2007 14 International Transfer Pricing Journal79Google Scholar
‘A Critique of Double Tax Treaties as a Jurisdictional Coordination Mechanism’ 1991 8 Australian Tax Forum301Google Scholar
‘The David R. Tillinghast Lecture: International Tax Arbitrage and the “International Tax System”’ 2000 53 Tax Law Review137Google Scholar
‘United States Tax Treaty Policy: An Overview’ 1981 19 Columbia Journal of Transnational Law359Google Scholar
???International Tax Law: The Need for Constructive Change???Tax Policy in the Twenty-First CenturyNew YorkWiley 1988 87Google Scholar
???The Future of the Treaty Rules for Taxing Business Profits???2000 World Tax Conference ReportTorontoCanadian Tax Foundation 2000 5 1Google Scholar
‘International Aspects of the Taxation of Corporations and Shareholders’ 1975 22 International Monetary Fund Staff Working Papers384CrossRefGoogle Scholar
‘Why Worldwide Welfare as a Normative Standard in US Tax Policy?’ 2007 60 Tax Law Review155Google Scholar
‘The David R. Tillinghast Lecture: What's Source Got to Do with It? Source Rules and US International Taxation’ 2002 56 Tax Law Review81Google Scholar
2009
Taxation of Multinational Corporations. The Impact of Multinational Corporations on Development and on International RelationsNew YorkUnited Nations 1974Google Scholar
???Introduction???Tax Progressivity and Income InequalityCambridgeCambridge University Press 1994 1CrossRefGoogle Scholar
‘Globalization of Transnational Business: The Challenge for International Tax Policy’ 1997 25 International Tax Review143Google Scholar
‘A Common Consolidated Corporate Tax Base for Multinational Companies in the European Union: Some Issues and Options’ 2007 Oxford University Centre for Business TaxationGoogle Scholar
‘Current Issues in the Taxation of Corporate Foreign Investment’ 1956 56 Columbia Law Review815CrossRefGoogle Scholar
‘Reflections on the Allocation of Income and Expenses Among National Tax Jurisdictions’ 1978 10 Law and Policy in International Business409Google Scholar
‘United Nations Group of Experts and the Guidelines for Tax Treaties Between Developed and Developing Countries’ 1978 19 Harvard International Law Journal1Google Scholar
???Forces that Shape Tax Policy???Tax Policy in the Twenty-First CenturyNew YorkWiley 1988 266Google Scholar
1996
‘The Nature and Effects of Globalization on International Tax Policy, Technological Developments, and the Work of Fiscal Termites’ 2001 26 Brooklyn Journal of International Law1261Google Scholar
‘Customary International Law and State Taxation of Corporate Income: The Case for the Separate Accounting Method’ 1996 14 Berkeley Journal of International Law99Google Scholar
‘International Tax Cooperation and a Multilateral Treaty’ 2001 26 Brooklyn Journal of International Law1641Google Scholar
2002
World Investment Report: Transnational Corporations, Agricultural Production and DevelopmentNew York and GenevaUN 2009Google Scholar
World Investment Report: Transnational Corporations, and the Infrastructure ChallengeNew York and GenevaUN 2008Google Scholar
Draft Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing CountriesNew YorkUN 2001Google Scholar
International Co-operation in Tax Matters, Guidelines for International Co-operation Against the Evasion and Avoidance of Taxes (with Special Reference to Taxes on Income, Profits, Capital and Capital Gains)New YorkUN 1984Google Scholar
United Nations Conference on the Law of Treaties, First and Second Sessions, Official RecordsNew YorkUN 1971Google Scholar
United Nations Model Double Taxation Convention between Developed and Developing CountriesNew YorkUN 1980Google Scholar
United Nations Model Tax Convention Between Developed and Developing CountriesNew YorkUN 2001Google Scholar
World Investment Report 1993: Transnational Corporations and Integrated ProductionNew YorkUN 1993Google Scholar
2004
Corporate Inversion Transactions: Tax Policy ImplicationsWashingtonDepartment of Treasury 2002Google Scholar
‘Corporate Inversion Transactions: Tax Policy Implications’ reproduced in 2002 Worldwide Tax Daily 103???38Google Scholar
Report to Congress on Earning Stripping, Transfer Pricing and US Income Tax TreatiesWashingtonUS Department of the Treasury 2007Google Scholar
Income Shifting from Transfer Pricing: Further Evidence from Tax Return DataWashingtonUS Department of the Treasury 2008Google Scholar
Selected Tax Policy Implications of Global Electronic CommerceWashingtonUS Department of Treasury 1996Google Scholar
The Deferral of Income Earned Through US Controlled Foreign Corporations: A Policy StudyWashingtonOffice of Tax Policy, Department of the Treasury 2000Google Scholar
International Taxation: Problems Persist in Determining Tax Effects of Intercompany PricesWashingtonUnited States General Accounting Office 1992Google Scholar
IRS Could Better Protect US Tax Interests in Determining the Income of Multinational CorporationsWashingtonGeneral Accounting Office 1981Google Scholar
2008
2006
2006
Simple, Fair, and Pro-Growth: Proposals to Fix America's Tax SystemWashingtonPresident's Advisory Panel on Federal Tax Reform 2005Google Scholar
???Legal Framework for Taxation???Tax Law Design and DraftingWashingtonInternational Monetary Fund 1996 15Google Scholar
‘A Model Tax Treaty for the Asian-Pacific Region? (Part I)’ 1991 45 Bulletin for International Fiscal Documentation99Google Scholar
‘A Model Tax Treaty for the Asian-Pacific Region (Part II)’ 1991 45 Bulletin for International Fiscal Documentation151Google Scholar
‘Do We Need 7(3)? History and Purpose of the Business Profits Deduction Rule in Tax Treaties’Cambridge 2010Google Scholar
???International Aspects of Income Tax???Tax Law Design and DraftingWashingtonInternational Monetary Fund 1998 718Google Scholar
???Reflections on Business Profits and the Arm's Length Principle???The Taxation of Business Profits Under Tax TreatiesTorontoCanadian Tax Foundation 2003 133Google Scholar
‘Double Tax Treaties and their Interpretation’ 1986 4 International Tax and Business Lawyer4Google Scholar
‘The Influence of the OECD Commentaries on Treaty Interpretation’ 2000 54 Bulletin for International Fiscal Documentation612Google Scholar
‘Worldwide vs. Source Taxation of Income – A Review and Re-evaluation of Arguments (Part I)’ 1988 16 Intertax216Google Scholar
‘Worldwide vs. Source Taxation of Income – A Review and Re-evaluation of Arguments (Part III)’ 1988 16 Intertax310Google Scholar
‘The Legal Status of the OECD Commentary and Static or Ambulatory Interpretation of Tax Treaties’ 2003 57 Bulletin for International Fiscal Documentation222Google Scholar
2005
‘EU Commission, Member States Commit to EU-Wide Company Taxation, Formulary Apportionment’ 2002 26 Tax Notes International515Google Scholar
‘Redirecting the Debate on Formulary Apportionment’ 2007 46 Tax Notes International1213Google Scholar
Using the Experience in the US States to Evaluate Issues in Implementing Formula Apportionment at the International LevelUS Department of TreasuryWashington83 1999Google Scholar
‘Unitary Taxation: Its History and Recent Supreme Court Treatment’ 1983 48 Albany Law Review48Google Scholar
‘Tax Policy Forum – New Directions Needed for Solution of the Transfer Pricing Puzzle’ 1992 5 Tax Notes International399Google Scholar
Governing Global Banking, The Basel Committee and the Politics of Financial GlobalisationHampshireAshgate Publishing 2005Google Scholar
Understanding the WTOGenevaWorld Trade Organization 2010 www.wto.org/english/thewto_e/whatis_e/tif_e/understanding_e.pdfGoogle Scholar
The OECD's Proposed Article 7: A Work in Progress with an Uncertain FutureKPMGWashington National Office 2009Google Scholar