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Brain Drain Taxation as Development Policy UF Law Faculty Publications (2010)
This article examines the potential use of taxation to generate development funds in connection with the immigration of skilled immigrants from developing into developed countries, known as the "brain drain," if designed according to the ...
A Framework for an Informed Study of the Realistic Role of Tax in a Development Agenda UF Law Faculty Publications (2010)
This article builds on the insights of this development research to develop a new agenda for tax incentives (and equivalent tax measures), the research of their merits when used by developing countries, and their optimal ...
Value in the Eye of the Beholder: The Valuation of Intangibles for Transfer Pricing Purposes UF Law Faculty Publications (2008)
This article assesses the desirability of our current, arms' length based, transfer pricing regime by analyzing its theoretical and practical effectiveness in application to transfers of intangibles. A detailed analysis of the practice of valuation ...
The Non-Sense Tax: A Reply to New Corporate Income Tax Advocacy UF Law Faculty Publications (2008)
This Article challenges recent attempts by influential scholars to rationalize the existence of the corporate income tax. The corporate income tax has long been considered unjustifiable on traditional tax policy grounds. The new justifications recognize ...
Integration in an Integrating World UF Law Faculty Publications (2005)
During the second half of the last century, many countries gradually replaced their so-called classical corporate tax regimes, under which corporate earnings were taxed twice -- once in the hands of the corporation, and again ...
International Trade and Tax Agreements May Be Coordinated, But Not Reconciled UF Law Faculty Publications (2005)
A recent WTO case held the U.S.' export tax subsidies illegal. Despite strong political resistance, which fed a long and costly legislative process, the U.S. recently repealed these subsidies. This case and the U.S. reaction ...
A Good Old Habit, or Just an Old One? Preferential Tax Treatment for Reorganizations UF Law Faculty Publications (2004)
This article proposes to repeal the preferential tax treatment of certain merger and acquisition transactions known as "reorganizations," and tax them like all other sales or exchanges. In the last 80 years this preference has ...
An International Tax Regime in Crystallization UF Law Faculty Publications (2003)
The grand illusion of a single, worldwide, tax system that will eliminate all international inefficiencies, and assist all the nations of the world to maximize their relative advantages, is, as commonly accepted, utopian. The tax, ...