1,720,973 research outputs found
Recommended from our members
INTER-NATION EQUITY REVISITED
No full textStates are on the verge of a new form of global competition. Some have taken unilateral measures to tax multinational profits that they would typically not be able to tax, at least not according to conventional international tax concepts and rules. Others have threatened to retaliate with economic countermeasures to protect their tax base and corporate residents. The recent attempt of the OECD to build consensus for a global tax compact has so far proven unsuccessful due to broad disagreement about how taxing rights should be equitably distributed between countries.
As policymakers and tax scholars increasingly call into question long-standing theories of international taxation, the concept of inter-nation equity plays a pivotal role as a guiding principle in determining how to divide the international tax base among states. Inter-nation equity is one of the most ubiquitous concepts appearing in international tax policy discussions and yet one of the most understudied in tax scholarship.
This Article introduces a comprehensive normative analysis of inter-nation equity by discussing how the concept should reconcile the two primary goals of international allocation of taxing rights: on the one hand, the concern of states to preserve their tax sovereignty and, on the other hand, the need to promote some degree of redistribution to address the challenges of global poverty and inequality. This Article further explains how a similar notion of inter-nation equity has developed in other areas of international law and discusses some practical implications for tax policy design
INTER-NATION EQUITY REVISITED
No full textStates are on the verge of a new form of global competition. Some have taken unilateral measures to tax multinational profits that they would typically not be able to tax, at least not according to conventional international tax concepts and rules. Others have threatened to retaliate with economic countermeasures to protect their tax base and corporate residents. The recent attempt of the OECD to build consensus for a global tax compact has so far proven unsuccessful due to broad disagreement about how taxing rights should be equitably distributed between countries.
As policymakers and tax scholars increasingly call into question long-standing theories of international taxation, the concept of inter-nation equity plays a pivotal role as a guiding principle in determining how to divide the international tax base among states. Inter-nation equity is one of the most ubiquitous concepts appearing in international tax policy discussions and yet one of the most understudied in tax scholarship.
This Article introduces a comprehensive normative analysis of inter-nation equity by discussing how the concept should reconcile the two primary goals of international allocation of taxing rights: on the one hand, the concern of states to preserve their tax sovereignty and, on the other hand, the need to promote some degree of redistribution to address the challenges of global poverty and inequality. This Article further explains how a similar notion of inter-nation equity has developed in other areas of international law and discusses some practical implications for tax policy design
Going Beyond Counting First Authors in Author Co-citation Analysis
No full textThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Crítica à interpretação privatista no pensamento tributário brasileiro = A critique of the private law approach to tax interpretation in Brazilian scholarship
No full textA Critique of the Private Law Approach to Tax Interpretation in Brazilian Scholarship
No full textIn this paper, I point out that since the late 1960s, Brazilian tax law scholarship has increasingly rejected any attempt to integrate economic perspectives in the interpretation of tax legislation. The prevailing theory suggests that tax jurisdictions established in the Brazilian Constitution should be interpreted based on concepts from private law and should disregard any consideration of the economic context referred to by the constitutional legislator. Building on Luhmann’s systems theory, which suggests that operational closure of the legal system requires cognitive openness to other social subsystems, I argue that the predominant Brazilian tax theory (which I call private law approach) gives rise to two central problems. First, it reinforces an unseemly propensity toward literal interpretation. Second, by repudiating the economic context envisaged by the constitutional legislator, Brazilian tax scholarship fails to fulfill its primary role of describing the law and thereby stabilizing normative expectations
Implementing a Differential Carbon Border Adjustment Mechanism: How to Design a CBAM Compliant with International Law
No full textVariations on the Author
No full text“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
No full textWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
Recommended from our members
Designing an Equitable Border Carbon Adjustment Mechanism
No full textPolicy makers worldwide have increasingly considered the adoption of a carbon adjustment at the border to equalize carbon pricing on foreign goods with carbon policies imposed on domestic production. The implementation of a border carbon adjustment (BCA) in the European Union has been recently proposed by the European Commission, followed by similar plans in the United States and Canada, as an instrument designed to address concerns about competitiveness and emissions leakage resulting from the absence of a global price on carbon or an internationally coordinated carbon-pricing system. Despite its potential to address these issues, the implementation of a BCA raises concerns with respect to its impact on developing countries. A BCA will likely impose a disproportionate burden on developing countries with limited capacity to cut back emissions and thus violate the principle of common but differentiated responsibilities (CBDR) established in the United Nations Framework Convention on Climate Change. The main goal of this article is to examine CBDR’s normative requirements and determine its legal implications for BCA design. The article further offers policy guidelines for implementing a CBDR-compliant BCA that addresses its ultimate purpose of reducing global greenhouse gas emissions while also supporting the development needs of less affluent countries
- …
