000			01679nab a2200217 c 4500
999			_c141591 _d141591
003			ES-MaIEF
005			20210824122133.0
007			ta
008			200110t2019 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100	1		_928872 _aMazzoni, Gianluca
245		0	_aPresent at the creation _bachival research and evidence on the origins of the single tax principle _c Gianluca Mazzoni
260			_c2019
500			_aResumen.
520			_aThe 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to contextualize and provide a historical background for the single tax principle by guiding the readers through these unpublished materials.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.
650		4	_948067 _aFISCALIDAD INTERNACIONAL
650		4	_aTIPO MÍNIMO GLOBAL _967681
773	0		_9161586 _oOP 2141/2019/10 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 47, issue 10, October 2019, p. 813-831
942			_cART