Publicity about tax avoidance techniques of multinational corporations and wealthy individuals has moved discussion of international income taxation from the backrooms of law and accounting firms to the front pages of news organizations around the world. In the words of a top Australian tax official, international tax law has now become a topic of barbeque conversations. Public anger has, in turn, brought previously arcane issues of international taxation onto the agenda of heads of government around the world. Despite all the attention, however, issues of international income taxation are often not well understood. In this collection of essays, written over the past two decades, renowned tax expert Michael J. Graetz reveals how current international tax policy came into place nearly a century ago, critiques the inadequate principles still being used to make international tax policy, identifies and dissects the most prevalent tax avoidance techniques, and offers important suggestions for reform. This book is indispensable for anyone interested in international income taxation.
Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
This dissertation is composed of three chapters. All three deal with topics in development economics. The first chapter examines the effects on village institutions of introducing formal financial institution options into the village. The second addresses the effects of government policy on educational investment and crime. The third tests the explanatory power of various explanations of the gender gap in math test scores. The first chapter examines the effects of a transition from a ``traditional'' economy based on an uncertain source of income, with risk fully insured away by one's neighbors in a social network through costly network ties, to a ``modern'' economy in which some agents have access to partial insurance at a lower cost. A theoretical model is used to show that village social networks can break down as some members of the village no longer need the insurance the social network provides, producing a reduction in welfare (if the costs of reducing moral hazard are not too high) for at least some individuals and possibly the village as a whole. This loss of welfare can occur even when networks provide other benefits to those belonging to them and is likely to be heterogeneous, depending on the opportunities and networks available to individuals. This paper tests these predictions using Indonesian data to examine the effect of a change in the banking institutions available to a community on the strength of social networks (measured by community participation) and welfare (measured by household expenditure and by child health). The analysis finds that changing financial institution availability in general does not influence community participation or welfare, but that financial institutions that primarily serve certain groups do relatively reduce the welfare of households not in those groups, which is consistent with the hypotheses generated by the model. Crime is an important feature of economic life in many countries, especially in the developing world. Crime distorts many economic decisions because it acts like an unpredictable tax on earnings. In particular, the threat of crime may influence people's willingness to invest in schooling or physical capital. The second chapter explores the questions "What influence do crime rates and levels of investment have on one another?" and "How do government policies affect the relationship between investment and crime?" by creating a simple structural model of crime and educational investment and attempting to fit this model to Mexican data. A method of simulated moments procedure is used to estimate parameters of the model and the estimated parameters are then used to carry out policy simulations. The simulations show that increasing spending on police or increasing the severity of punishment reduces crime but has little effect on educational investment. Increased educational subsidies increase educational investment but reduce crime only slightly. Thus, one type of policy is insufficient to accomplish the goals of both reducing crime and increasing education. The third chapter is joint work with Prashant Bharadwaj, Giacomo De Giorgi, and Christopher Neilson. Boys tend to have better performances than girls in mathematical testing; in particular, there are significantly more boys than girls among high achievers and the score distribution appears to have a longer right tail for boys. We confirm such results on several low- and middle-income countries. In particular we find that the gender gap is already present by age 10 and substantially increases by age 14 and 15. We propose and try to test a series of explanations for such a gap: (i) parental investment, (ii) ability, (iii) school resources, (iv) individual investment and effort (not tested directly), (v) competitive environment, and (vi) cultural norms. We conclude that none of our proposed explanations can account for a substantial portion of the gap.
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
The integration of accounting and the economics of information developed by Joel S. Demski and those he inspired has revolutionized accounting thought. This volume collects papers on accounting theory in honor of Professor Demski. The book also contains an extensive review of Professor Demski’s own contributions to the theory of accounting over the past four decades.
