The winners of the Worldwide Fiscal Affiliation’s 2021 Worldwide Tax Scholar Writing Competitors are:
Mohanad Salaimi (Michigan), Company Inversions: Getting on the Tax Reform Prepare Earlier than It Leaves the Station, 41 Va. Tax Rev. ___ (2022) (Winner, 2021 Tannenwald Tax Writing Competitors)
College Sponsor: Reuven Avi-Yonah
The Article brings a tax problem of utmost significance to the foreground. The Article addresses the company inversion phenomenon and why it occurred within the U.S. prior to now many years.
The Article traces the historical past of inversions within the U.S. to focus on among the important classes they supply. It additionally offers with the U.S. tax system’s response to this tax planning approach as mirrored by the event of the anti-inversion guidelines which tried to curb such phenomenon.
The Article places ahead that coverage discussions on inversions ought to inform themselves with the historical past of this phenomenon and causes that accounted for the U.S. MNEs’ selections to expatriate during the last many years
Nory Dianne R. Miano (Georgetown), Debt vs. Fairness Financing and Enterprise Taxation in a Publish-BEPS/Anti-Tax Avoidance Directive/Corona World, 51 BNA Tax Mgmt. Int’l J. 1 (2022)
College Sponsor: Stafford Smiley
Everybody needs to be wealthy. However, do you wish to be wealthy in debt or wealthy in fairness? In case you are a taxpayer in america (“US”), let me show you how to determine. This paper goals to explain how tax guidelines relating to debt and fairness financing are applied within the US. The totally different therapy of debt and fairness for revenue tax functions is likely one of the main issues of a rustic’s enterprise taxation system below home legal guidelines, worldwide legislation and relevant treaty legislation, which, below present US legal guidelines and tax guidelines, could give choice to 1 sort of financing over the opposite. So as to keep away from any “debt-equity bias,” accompanying tax guidelines and rules (“Reg.”) needs to be applied that are geared in the direction of bettering neutrality between each types of financing.
A company has two main sources of capital: (1) investor capital and (2) borrowed capital. Differentiating for federal revenue tax functions between these two varieties of capital has induced appreciable issue for a few years. The same old federal revenue tax planning strategy is to deal with capital as coming from borrowed sources as a result of (1) the price of such borrowing is a deductible expense to the borrower, and (2) that borrowed principal quantity may be repaid to the lender with out federal revenue tax penalties to the lender.
Half I of this paper provides an summary of the debt-equity bias within the US tax system. It’s adopted by a background of enterprise taxation below US home legal guidelines in Half II. The writer dives deeper in Half III and Half IV to a extra detailed dialogue of debt financing and fairness financing, with an interaction of the connection of US home tax legal guidelines with the worldwide tax guidelines on Base Erosion and Revenue Shifting (“BEPS”) and the Anti-Tax Avoidance Directive (“ATAD”). Half V then takes us to the post-Corona world to see how the pandemic has impacted the principles on debt and fairness financing. After analyzing neutrality and enterprise taxation within the US, the writer wraps it up with Half VI for her evaluation and personal suggestions to realize tax neutrality.
2022 IFA Worldwide Tax Scholar Writing Competitors
Topic: Any subject referring to U.S. taxation of revenue from worldwide actions, together with taxation below U.S. tax treaties.
Open to: All college students in the course of the 2021-22 educational 12 months pursuing a graduate diploma. Any acceptable papers written in fall 2021 or spring and summer season 2022.
Submission Deadline: September 30, 2022.
Prize: $5,000 money, plus expenses-paid invitation to the IFA USA Department Annual Assembly in April 2023. The college advisor of the profitable submission may also obtain an expenses-paid invitation to the annual assembly.
Listed below are the current winners:
- 2020: Shay Moyal (S.J.D. 2020, Michigan; Davis Polk & Wardwell, New York), Don’t Cease the Beat, 166 Tax Notes Fed. 721 (Feb. 3, 2020)
- 2019: David Rubin (Virginia), EB OR NOT EB? That’s the Query Treasury Should Reply After Brexit, 49 BNA Tax Mgmt. Int’l J. 1 (2020)
- 2018: Ivan Ozawa Ozai (LL.B. 2019, McGill), Tax Competitors and the Ethics of Burden Sharing, 42 Fordham Int’l J. 61 (2018).
- 2017: David Maranjian (J.D. 2017, Virgina), What’s in a Identify? XILINX, ALTERA, and Why Utilizing “Arm’s Size” as a Catchall is Inflicting Issues for Treasury, 47 BNA Tax Mgmt. Int’l J. ___ (2018)
- 2016: Amanda Kazacos (LL.M. 2016, NYU), BEPS Motion 6: The Precept Objective Take a look at Revisited, and Amanda M. Leon (J.D. 2016, College of Virginia), If the Fee “LOBs” a Pitch to the ECJ, Will It Strike Out Once more? Reconsidering European Courtroom of Justice Jurisprudence Concerning Limitation on Advantages Clauses in Bilateral Tax Treaties and Why america Ought to Care.
- 2015: Sienna Carly White (J.D. 2015, Notre Dame), Price Sharing Agreements & the Arm’s Size Normal: A Matter of Statutory Interpretation?, 19 Fla. Tax Rev. 191 (2016).
- 2014: Mateusz M. Krauze (LL.M. 2014, Harvard), Impression of Cloud Computing on Everlasting Institutions below the OECD Mannequin Tax Conference, 44 TM Int’l J. 44 (2015).
- 2013: Benjamin B. Vick (J.D. 2013, Boston College), Associated-Social gathering Transfers of Intangibles: Requirements and Suggestions for Combating Worldwide Switch Pricing Abuses, 43 TM Int’l J. 207 (2014).
- 2012: Assaf Prussak (S.J.D. Candidate, Michigan), The Earnings of the twenty first Century: On-line Promoting as a Case Research for The Implications of Expertise for Supply-Primarily based Taxation, 16 Tul. J. Tech. & Intell. Prop. (2013).
- 2011: Bradford Craig (J.D. 2012, Temple), Congress, Have a Coronary heart: Sensible Options to Punitive Measures Plaguing the Coronary heart Act’s Expatriate Inheritance Tax, 26 Temp. Int’l & Comp. L.J. 69 (2012).
- 2010: Kevin L. Preslan (J.D. 2011, Cleveland State), Turnabout is Truthful Play: The U.S. Response to Mexico’s Request for Financial institution Account Info, 1 World Bus. L. Rev. 203 (2011).
- 2009: Samuel J. Lee (LL.M. 2009, Boston College), A Suggestion, in Mild of the Present Economic system, for Revising the Method § 304 Applies to Worldwide Transactions, 38 Tax Mgmt. Int’l J. 500 (Aug. 2009).
- 2008: Jason Sullivan (LL.M. 2008, Florida), Debt-Fairness Hybrid Devices in a Cross-Border Setting: A Concentrate on the U.S. International Tax Credit score, 53 Tax Notes Int’l 817 (Mar. 2, 2009).
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