Formulary Apportionment – is this Alternative to the Arm’s Length Standard Possible and Practical Under the United States’ Current Tax Treaties?

1997 ◽  
pp. 166-187
Keyword(s):  
United States ◽  
The United States ◽  
Tax Treaties ◽  
Length Standard

scholarly journals A perfect symbiosis: Curaçao, the Netherlands and financial offshore services, 1951–2013

2021 ◽  
pp. 1-29
Author(s):  
Tijn van Beurden ◽  
Joost Jonker
Keyword(s):  
United States ◽  
The Netherlands ◽  
Competitive Advantage ◽  
Tax Avoidance ◽  
The United States ◽  
Tax Treaties ◽  
Gradual Decline ◽  
Western Countries ◽  
Financial Centre ◽  
The One

Analysing Curaçao as an offshore financial centre from its inception to its gradual decline, we find that it originated and evolved in close concert with the demand for such services from Western countries. Dutch banks and multinationals spearheaded the creation of institutions on the island facilitating tax avoidance. In this they were aided and abetted by their government, which firmly supported the Antilles in getting access to bilateral tax treaties, notably the one with the United States. Until the mid 1980s Curaçao flourished, but then found it increasingly difficult to keep a competitive advantage over other offshore centres. Meanwhile the Curaçao connection had enabled the Netherlands to turn itself into a hub for international revenue flows that today still feed both Dutch tax income and specialised financial, legal and accounting services.

A Formula for Tax-Sparing Credits in U.S. Tax Treaties with Developing Countries

1978 ◽  
Vol 72 (2) ◽  
pp. 296-316
Author(s):  
Howard M. Liebman
Keyword(s):  
United States ◽  
Foreign Relations ◽  
The United States ◽  
Tax Treaties ◽  
Double Taxation ◽  
Senate Committee ◽  
United Arab Republic ◽  
Incentive Program ◽  
Tax Incentive ◽  
Developed Nations

On July 1, 1957, the United States and Pakistan signed a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income. Although, at that time, it was one of the few double taxation treaties that the United States had entered into with a developing country, it followed, for the most part, the template established by earlier tax treaties negotiated with the more developed nations. A major distinguishing factor, however, was the inclusion of a tax-sparing credit provision, by means of which the coverage of the foreign tax credit accorded U.S. taxpayers for certain foreign taxes paid or deemed to have been paid was extended to certain taxes that were ordinarily levied by Pakistan but which had been “spared” as part of the latter’s incentive program for the stimulation of economic development. Three other treaties—with India, Israel, and the United Arab Republic—presented to the Senate for ratification at approximately the same time also contained tax-sparing provisions. However, none of these tax-sparing provisions was ever put into effect. The Convention with Pakistan was approved with a reservation excluding the sparing provisions, on the basis that the Pakistani tax concession which was to be credited for “phantom” taxes deemed paid had expired. The other three treaties never received the assent of the Senate and were subsequently withdrawn from the Senate Committee on Foreign Relations in 1964. No other tax-sparing provisions have been negotiated by the United States, although other tax incentive schemes have been presented to the Senate. These, too, have failed to be approved. The failure to agree to any such provision utilizing tax incentives as a form of development assistance is often deemed to be the major reason for the notable dearth of tax conventions between the United States and the developing states, as the latter are particularly interested in the inclusion of tax-sparing credit provisions in the double taxation treaties that they agree to sign. This failure is, in turn, rooted in the severe and at times persuasive criticism levied against the principle of granting tax-sparing credits—especially in the form in which they were to be granted in the four aforementioned treaties—and in the consequent hostility of the Senate Committee on Foreign Relations, as perceived by those responsible for negotiating U.S. tax treaties, toward provisions of this sort.

Party Strength in the United States: Some Corrections

1975 ◽  
Vol 37 (2) ◽  
pp. 641-642 ◽  
Author(s):  
Paul T. David
Keyword(s):  
United States ◽  
The United States ◽  
Party Strength

Correlative microscopy in distrubuted (client/server) computing environments: tools for catalyzing the rapid dissemination of information about the cell biology of the human prostate

1995 ◽  
Vol 53 ◽  
pp. 682-683
Author(s):  
A. Hakam ◽  
J.T. Gau ◽  
M.L. Grove ◽  
B.A. Evans ◽  
M. Shuman ◽  
...  
Keyword(s):  
United States ◽  
Cell Biology ◽  
Tissue Bank ◽  
The United States ◽  
Prostate Adenocarcinoma ◽  
Correlative Microscopy ◽  
Client Server ◽  
Critical Elements ◽  
Transplant Organ

Prostate adenocarcinoma is the most common malignant tumor of men in the United States and is the third leading cause of death in men. Despite attempts at early detection, there will be 244,000 new cases and 44,000 deaths from the disease in the United States in 1995. Therapeutic progress against this disease is hindered by an incomplete understanding of prostate epithelial cell biology, the availability of human tissues for in vitro experimentation, slow dissemination of information between prostate cancer research teams and the increasing pressure to “ stretch” research dollars at the same time staff reductions are occurring.To meet these challenges, we have used the correlative microscopy (CM) and client/server (C/S) computing to increase productivity while decreasing costs. Critical elements of our program are as follows:1) Establishing the Western Pennsylvania Genitourinary (GU) Tissue Bank which includes >100 prostates from patients with prostate adenocarcinoma as well as >20 normal prostates from transplant organ donors.

Digital image acquisition, processing, and analysis in a polymer microscopy laboratory

1994 ◽  
Vol 52 ◽  
pp. 454-455
Author(s):  
Vinod K. Berry ◽  
Xiao Zhang
Keyword(s):  
United States ◽  
Image Analysis ◽  
Digital Image ◽  
Image Acquisition ◽  
Image Transmission ◽  
The United States ◽  
Quantitative Image Analysis ◽  
Quantitative Image

In recent years it became apparent that we needed to improve productivity and efficiency in the Microscopy Laboratories in GE Plastics. It was realized that digital image acquisition, archiving, processing, analysis, and transmission over a network would be the best way to achieve this goal. Also, the capabilities of quantitative image analysis, image transmission etc. available with this approach would help us to increase our efficiency. Although the advantages of digital image acquisition, processing, archiving, etc. have been described and are being practiced in many SEM, laboratories, they have not been generally applied in microscopy laboratories (TEM, Optical, SEM and others) and impact on increased productivity has not been yet exploited as well.In order to attain our objective we have acquired a SEMICAPS imaging workstation for each of the GE Plastic sites in the United States. We have integrated the workstation with the microscopes and their peripherals as shown in Figure 1.

Silence of the Land: On the Historical Irrelevance of Territory to Congressional Districting and Political Representation in the United States

2001 ◽  
Vol 15 (01) ◽  
pp. 53-87 ◽  
Author(s):  
Andrew Rehfeld
Keyword(s):  
United States ◽  
House Of Representatives ◽  
Political Representation ◽  
The United States ◽  
Representative Government ◽  
Congressional District ◽  
Congressional Districts ◽  
Communities Of Interest

Every ten years, the United States “constructs” itself politically. On a decennial basis, U.S. Congressional districts are quite literally drawn, physically constructing political representation in the House of Representatives on the basis of where one lives. Why does the United States do it this way? What justifies domicile as the sole criteria of constituency construction? These are the questions raised in this article. Contrary to many contemporary understandings of representation at the founding, I argue that there were no principled reasons for using domicile as the method of organizing for political representation. Even in 1787, the Congressional district was expected to be far too large to map onto existing communities of interest. Instead, territory should be understood as forming a habit of mind for the founders, even while it was necessary to achieve other democratic aims of representative government.

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