RESTRAINING HARMFUL TAX COMPETITION: AN ANALYSIS OF AMERICAN CFC LEGISLATION
Capital and labor mobility facilitates cross-border activities of enterprises. In the era of globalization the optimal choice of investment location gives enterprises an opportunity to profit maximization. As a result the governments competing for foreign direct investment offer to enterprises preferential tax treatment. In order to minimize the loss of tax revenue countries imposing high effective tax rates on enterprises implement diversified anti-tax-avoidance measures. One of these measures is controlled foreign corporation. The article examines the application of the controlled foreign corporation rules in the United States of America to combat harmful tax competition. It has to be underlined, that the American controlled foreign corporation legislation was a prototype for other countries that use this institution to prevent tax avoidance. The aim of this article is to review the controlled foreign corporation legislation in the USA, analyze the structure of CFCs and the structure of their subpart F income in this country and evaluate the efficiency of this anti-tax-avoidance measure. The author describes inter alia, implications of harmful tax competition and the CFC rules. As the provisions of controlled foreign corporation are also planned to be introduced in Poland, the American legislation might be a good example of its successful implementation.
Taxing International Income: an Analysis of the U.S. System and its Economic Premises
This paper describes the basic U.S. legal rules that govern the taxation of international transactions and explores the economic policies or principles they reflect. Particular attention is paid to the changes made by the Tax Reform Act of 1986, but it is impossible to understand the 1986 Act changes without placing them in the context of the general taxing system applicable to international transactions. The exposition is intended to be intelligible to readers with either legal or economic training.
Graduate students’ experiences with standardized patients as adjuncts for teaching pelvic examinations
Purpose: To explore graduate nurse practitioner students’ perceptions of their experiences when learning to perform pelvic examinations in the laboratory and performing them in subsequent clinical rotations. One group was taught by faculty with voluntary peer examination, and the other two groups were taught by standardized patients (SPs). Data sources: Surveys with open‐ and closed‐ended (responses on Likert scales) items administered twice during 3 consecutive years to students enrolled in an advanced health assessment course. Conclusions: All groups reported feeling anxious while learning pelvic exam techniques and in subsequent clinical experiences. SPs provided immediate feedback to students, decreased their feelings of anxiety, and increased their confidence in performing examinations. Students who were taught pelvic examination techniques by SPs rated their learning experiences more positively and reported a better understanding of exam techniques than students who learned to perform exams by voluntary examination of classmates. Implications for practice: Graduate nursing programs should consider locating and using SP programs for teaching pelvic examinations in advanced health assessment courses. Although more cost‐effective, voluntary peer examination was a less effective teaching method.