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.
An Analysis of Where American Companies Report Profits: Indications of Profit Shifting
This report uses data on the operations of U.S. multinational companies (MNCs) to examine the extent to which, if any, MNCs are moving profits out of high-tax countries (or out of the U.S.) and into low-tax countries with little corresponding change in business operations, a practice known as "profit shifting."
Two weddings and a lawsuit: Marriage litigation in fourteenth-century Portugal
Based on one of the few surviving records of marriage cases brought before
 ecclesiastical courts in fourteenth-century Portugal, this article offers a rare
 glimpse of marriage practice in a small village in a remote corner of Western Europe
 and the complex ties that bound its inhabitants and which secular and ecclesiastical
 authorities sought to regulate. Clear parallels can be drawn with the patterns of
 marriage litigation observed in England and Northern France, but evidence also
 suggests that royal legislation played an important part in the resolution of marital
 disputes and in the shaping of conjugal behaviour.