"A Model Tax Treaty for the Asia-Pacific Region?"
|
(1991) 45 Bulletin for International Fiscal Documentation 99
|
Bulletin for International Fiscal Documentation
|
|
circa 1991
|
|
|
3
|
"A Modified Fractional Apportionment Proposal for Tax Transfer Pricing"
|
(1992) 54 Tax Notes 719
|
Tax Notes
|
United States
|
circa 1992
|
|
|
1
|
"Arm ’ s-Length Pricing: Some Economic Perspectives"
|
(1992) 54 Tax Notes 731
|
Tax Notes
|
United States
|
circa 1992
|
|
|
1
|
"Back to the Future: A Path to Progressive Reform of the US International Income Tax Rules"
|
(1997) 51 University of Miami Law Review 975
|
University of Miami Law Review
|
United States
|
circa 1997
|
HeinOnline / LexisNexis
|
|
4
|
"Customary International Law and State Taxation of Corporate Income: The Case for the Separate Accounting Method"
|
(1996) 14 Berkeley Journal of International Law 99
|
Berkeley Journal of International Law
|
United States
|
circa 1996
|
HeinOnline / LexisNexis
|
|
1
|
"Developments in Transfer Pricing Enforcement and Complex Audit Strategy in the Australian Taxation Office"
|
(1988) 5 Australian Tax Forum 471
|
Australian Tax Forum
|
Australia
|
circa 1988
|
|
|
2
|
"Dorgan ’ s Charges of Transfer Pricing Abuse Unfounded"
|
(1999) 18 Tax Notes International 2263
|
Tax Notes International
|
United States
|
circa 1999
|
|
|
1
|
"Federal Income Taxation of Multinationals: Replacement of Separate Accounting with Formulary Apportionment"
|
(1993) 60 Tax Notes 1131
|
Tax Notes
|
United States
|
circa 1993
|
|
|
1
|
"Foreign Banks: Defining the Personality"
|
(1994) 48 Bulletin for International Fiscal Documentation 243
|
Bulletin for International Fiscal Documentation
|
|
circa 1994
|
|
|
1
|
"Global Profit Split: An Evolutionary Approach to International Income Allocation"
|
(2002) 50 Canadian Tax Journal 823
|
Canadian Tax Journal
|
Canada
|
circa 2002
|
|
|
1
|
"Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State"
|
(2000) 113 Harvard Law Review 1573
|
Harvard Law Review
|
United States
|
circa 2000
|
HeinOnline / LexisNexis
|
|
11
|
"Globalization, Technological Developments, and the Work of Fiscal Termites"
|
(2001) 26 Brooklyn Journal of International Law 1261
|
Brooklyn Journal of International Law
|
United States
|
circa 2001
|
HeinOnline / LexisNexis
|
|
2
|
"Intercompany Transfer Pricing for the Layman"
|
(1990) 49 Tax Notes 211
|
Tax Notes
|
United States
|
circa 1990
|
|
|
1
|
"International Tax Issues Affecting Electronic Commerce and Banking"
|
(1997) 14 Tax Notes International 1619
|
Tax Notes International
|
United States
|
circa 1997
|
|
|
1
|
"International Transfer Pricing Rules: Unconventional Wisdom"
|
(1995) 2 ILSA Journal of International and Comparative Law 283
|
ILSA Journal of International and Comparative Law
|
United States
|
circa 1995
|
HeinOnline
|
|
3
|
"New Directions Needed for Solution of the Transfer Pricing Tax Puzzle"
|
(1992) 5 Tax Notes International 399
|
Tax Notes International
|
United States
|
circa 1992
|
|
|
2
|
"Past and Present Work in the OECD on Transfer Pricing and Selected Issues"
|
(1994) 9 Tax Notes International 249
|
Tax Notes International
|
United States
|
circa 1994
|
|
|
1
|
"Replacing Separate Entity Accounting and the Arm ’ s Length Principle with Formulary Apportionment"
|
(2002) 56 Bulletin for International Fiscal Documentation 586
|
Bulletin for International Fiscal Documentation
|
|
circa 2002
|
|
|
1
|
"Slicing the Shadow – The Continuing Debate Over Unitary Taxation and Worldwide Combined Reporting"
|
[1994] British Tax Review 572
|
British Tax Review
|
United Kingdom
|
circa 1994
|
Westlaw
|
|
1
|
"Taxation of Global Trading of Financial Instruments: A Discussion Draft by the OECD"
|
(1997) 8 Journal of Banking and Finance Law and Practice 130
|
Journal of Banking and Finance Law and Practice
|
Australia
|
circa 1997
|
Legal Online
|
|
2
|
"Taxation of Global Trading Operations: Use of Advance Pricing Agreements and Profit-Split Methodology"
|
(1995) 48 Tax Lawyer 1057
|
Tax Lawyer
|
United States
|
circa 1995
|
HeinOnline
|
|
3
|
"Taxing International Income: Inadequate Principles, Outdated Concepts, and Unsatisfactory Policies"
|
(2001) 26 Brooklyn Journal of International Law 1357
|
Brooklyn Journal of International Law
|
United States
|
circa 2001
|
HeinOnline / LexisNexis
|
|
5
|
"The Allocation of Income and Expenses Among Countries: Report on the Invitational Conference on Transfer Pricing"
|
(1993) 10 Australian Tax Forum 545
|
Australian Tax Forum
|
Australia
|
circa 1993
|
|
|
1
|
"The Interjurisdictional Allocation of Income and the Unitary Taxation Debate"
|
(1986) 34 Canadian Tax Journal 1337
|
Canadian Tax Journal
|
Canada
|
circa 1986
|
|
|
1
|
"The Interjurisdictional Allocation of Income"
|
(1986) 3 Australian Tax Forum 333
|
Australian Tax Forum
|
Australia
|
circa 1986
|
|
|
1
|
"The Unitary Method and the Myth of Arm ’ s Length"
|
(1986) 30 Tax Notes 625
|
Tax Notes
|
United States
|
circa 1986
|
|
|
2
|
"The Unspecific Federal Tax Policy of Arm ’ s Length: A Comment on the Continuing Validity of Formulary Apportionment at the Federal Level"
|
(1993) 60 Tax Notes 1147
|
Tax Notes
|
United States
|
circa 1993
|
|
|
1
|
"Transaction Cost, Production Cost, and Transfer Pricing"
|
(1989) 44 Tax Notes 1391
|
Tax Notes
|
United States
|
circa 1989
|
|
|
1
|
"Transfer Pricing Analysis of Global Trading Operations and Procedural Alternatives"
|
(1996) 74 Taxes The Tax Magazine 1129
|
Taxes: The Tax Magazine
|
United States
|
circa 1996
|
HeinOnline
|
|
1
|
"Transfer Pricing and the End of International Taxation"
|
(1999) 19 Tax Notes International 1201
|
Tax Notes International
|
United States
|
circa 1999
|
|
|
1
|
"Transfer Pricing Draft Rulings: Helpful Guidance or a Compliance Nightmare?"
|
(1996) 8 CCH Journal of Australian Taxation 30
|
CCH Journal of Australian Taxation
|
Australia
|
circa 1996
|
Informit
|
|
1
|
"Treating Tax Issues Through Trade Regimes"
|
(2001) 26 Brooklyn Journal of International Law 1683
|
Brooklyn Journal of International Law
|
United States
|
circa 2001
|
HeinOnline / LexisNexis
|
|
2
|
"Using NAFTA to Introduce Formulary Apportionment"
|
(1993) 6 Tax Notes International 851
|
Tax Notes International
|
United States
|
circa 1993
|
|
|
1
|
"Using the Experience in the US States to Evaluate Issues in Implementing Formula Apportionment at the International Level"
|
(1996) 13 Tax Notes International 2113
|
Tax Notes International
|
United States
|
circa 1996
|
|
|
1
|
[1994] International Tax Review 28
|
[1994] International Tax Review 28
|
International Tax Review
|
United Kingdom
|
circa 1994
|
HeinOnline
|
|
1
|
International Cooperation and Understanding: What's New About the OECD's Transfer Pricing Guidelines
|
(1996) 50 University of Miami Law Review 577
|
University of Miami Law Review
|
United States
|
circa 1996
|
HeinOnline / LexisNexis
|
|
2
|
Future of Source-Based Taxation of the Income of Multi-National Enterprises
|
(1993) 79 Cornell Law Review 18
|
Cornell Law Review
|
United States
|
circa 1993
|
HeinOnline / LexisNexis
|
|
3
|
Taxation Implications of Global Trading
|
(1990) 48 Tax Notes 1143
|
Tax Notes
|
United States
|
circa 1990
|
|
|
3
|
2 Act 1915
|
2 Act 1915
|
|
United Kingdom
|
circa 1915
|
|
|
69
|