|
|
The quest to tax interest income in a global economy: stages in the development of international income taxation.
- Article from:
-
Virginia Tax Review
- Article date:
-
January 1, 2008
- Author:
- Benshalom, llan
|
Copyright informationCOPYRIGHT 2008 Virginia Tax Review. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
|
TABLE OF CONTENTS
I.INTRODUCTION: WHY INTEREST? A PREFACE632
II. THE TAXATION OF DEBT INVESTMENT: THE 636
ISSUE IN CONTEXT
A. The Law and Economics of Inbound Debt636
Investments ...
B. Where Do We Go Now? 642
III THE REVENUE PHASE: FROM THE END OF WWI 644
UNTIL THE END OF WWII
IVTHE TRADE PHASE: POST-WWII TO 1990S 652
A. The Rationales of the "Trade 652
Argument"
B. U.S. Treaty Law 657
1. The U.S.-U.K. Double Taxation Treaty,660
1945
2. ...