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.
International Commercial Tax: Table of treaties
1. Fundamentals and sources of international tax law 2. The jurisdiction to tax 3. Source country taxation 4. Residence country taxation 5. The limited scope of treaties 6. Changes of source and residence 7. Bilateral administrative issues.
The lights that failed: European international history, 1919-1933
PART I: THE RECONSTRUCTION OF EUROPE, 1918-1929 1. The Hall of Mirrors: Peacemaking in the West 2. Distant Frontiers: Peacemaking in the East 3. Revolution from the Left: The Soviet Union and the Post-War Settlement 4. The Primacy of Economics: Reconstruction in Western Europe, 1919-1924 5. The Primacy of Nationalism: Reconstruction in Eastern and Central Europe 6. Revolution from the Right: Italy, 1919-25 7. The Geneva Dream: The League of Nations and Post-War Internationalism 8. New Dawn? Stabilisation in Western Europe after Locarno 9. Faltering Reconstruction: Cracks in the Locarno Facade 10. Troubled Waters: Uncertainties in Italy, Eastern Europe and the Soviet Union 11. Faltering Internationalism: Disarmament and Security after Locarno Conclusion: Europe Reconstructed? PART II: THE HINGE YEARS, 1930-1933 12. The Diplomacy of the Depression: Economics and Foreign Policy 13. Beyond Europe: The Manchurian Crisis 14. The Poisoned Chalice: The Pursuit of Disarmament Conclusion: The Hinge Years Appendices Select Bibliography