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1 May 2019, 10:42 am
Both tax treaties, and numerous countries' domestic income tax laws, treat the existence of a PE (or of something similar, such as a "U.S. trade or business" under U.S. income tax law) as a precondition to taxing non-resident companies on the profits that they earn from interacting with one's resident consumers and/or suppliers.Suppose one thinks that a PE really oughtn't to be necessary in order for a given country reasonably to tax non-resident companies… [read post]
14 Jun 2021, 3:58 am
What would you add to the above? [read post]
1 Nov 2013, 7:45 am
Beardsley Professor of Law, Emeritus, at Stanford Law School. [read post]
3 May 2018, 3:51 pm
The above does not, by itself, prove that the dissenting senators were wrong to object to the Mueller bill on constitutional grounds. [read post]
28 Jun 2023, 10:30 am
Loughlin notes that constitutionalism is usually taken to mean that the “main characteristics of a regime are defined by a founding text that is elevated above the ordinary cut and thrust of politics. [read post]
27 Jun 2013, 12:34 pm
Chiesi hired defendant Premier to build a database and conduct a study of the relative effectiveness of the different surfactants. [read post]
16 May 2017, 5:24 pm
” The plaintiffs’ bar’s relatively small is size and capacity for cohesiveness put the plaintiffs at a relative advantage to the defense bar. [read post]
8 May 2018, 9:30 pm
Antitrust law still exists to protect against unfair competition. [read post]
8 Jan 2010, 5:30 pm
Mill's analysis may go some way towards explaining the power of the Republican party in our society and the relative scarcity of Republicans in academia. [read post]
27 Jun 2023, 8:38 am
You may pay the nursing home; pay for an irrevocable funeral contract; or enter into a personal services contract with a relative who will assist the Medicaid recipient. [read post]
19 Apr 2022, 9:30 am
And the fact is that about 95 percent of Americans do not itemize their taxes, so even my relatively uncomplicated situation is at the worse end of the spectrum. [read post]
1 Nov 2022, 11:52 am
These are the people who convinced Clinton to guarantee his 1996 reelection by passing a slew of simply awful, regressive laws -- including the anti-immigrant IIRIRA, the anti-innocent AEDPA, the anti-everyone "ending welfare as we know it" law, and the anti-gay Defense of Marriage Act (DOMA). [read post]
12 Jan 2016, 7:54 am
The “specifics vary” supporting language made clear that the overall safety claim was relative to location, and its “aim to go above and beyond” language was aspirational, not factual. [read post]
16 Sep 2011, 12:23 pm
‘Law as an industry has sometimes felt itself to be overlooked in its treatment by government – certainly relative to financial services. [read post]
18 Feb 2024, 6:45 am
However, in the wake of the above Case, the notion of an implied jurisdiction agreement drew limited scholarly research attention (for instance, see Kennedy, (2023); Kupelyants, 2016). [read post]
19 Aug 2021, 3:55 am
If lawmakers were to change GILTI to resemble to the global minimum tax proposal, this could increase the tax liabilities of U.S. multinationals by $136.9 billion relative to current law. [read post]
12 Mar 2008, 3:17 pm
Moreover, the firms that acquired relatively more software patents tended to actually reduce their level of R&D spending relative to sales. [read post]
6 Mar 2011, 11:48 am
As stated above, this is not the end of this issue. [read post]
27 Sep 2024, 11:01 am
Much of this is relative. [read post]
27 Sep 2024, 11:01 am
Much of this is relative. [read post]
