Mazzoni, Gianluca
Present at the creation achival research and evidence on the origins of the single tax principle / Gianluca Mazzoni .-- , 2019
Resumen.
The purpose is to contextualize and provide a historical background for the single tax principle by guiding the readers through these unpublished materials. It aims at identifying who theorized (Clavier) and practically implemented (Thomas Adams) the single tax principle at the international level as well as at domestic level. The author shows how the single tax principle originated in 1927 when Clavier theorized that 'international incomes be prevented from escaping taxation altogether is as desirable as that the same income shall not be taxed by several different countries'; but only reached its maturity during the nine years 1957 - 1966 when Surrey, firstly, was successful in persuading Senate not to ratify Art. XV(I) of the Pakistan - US Income Tax Treaty (1957); secondly, adopted the Subpart F regime; thirdly, introduced the Investment or Holding Company article in the treaty with Luxembourg; and, finally, closed the loophole in the US-Canadian tax treaty.
FISCALIDAD INTERNACIONAL
TIPO MÍNIMO GLOBAL
Intertax 0165-2826 v. 47, issue 10, October 2019, p. 813-831
Present at the creation achival research and evidence on the origins of the single tax principle / Gianluca Mazzoni .-- , 2019
Resumen.
The purpose is to contextualize and provide a historical background for the single tax principle by guiding the readers through these unpublished materials. It aims at identifying who theorized (Clavier) and practically implemented (Thomas Adams) the single tax principle at the international level as well as at domestic level. The author shows how the single tax principle originated in 1927 when Clavier theorized that 'international incomes be prevented from escaping taxation altogether is as desirable as that the same income shall not be taxed by several different countries'; but only reached its maturity during the nine years 1957 - 1966 when Surrey, firstly, was successful in persuading Senate not to ratify Art. XV(I) of the Pakistan - US Income Tax Treaty (1957); secondly, adopted the Subpart F regime; thirdly, introduced the Investment or Holding Company article in the treaty with Luxembourg; and, finally, closed the loophole in the US-Canadian tax treaty.
FISCALIDAD INTERNACIONAL
TIPO MÍNIMO GLOBAL
Intertax 0165-2826 v. 47, issue 10, October 2019, p. 813-831