Number 2 - 2008 contains the following:
 

This article summarizes the proceedings of the joint IFA/OECD seminar at the IFA Congress in Kyoto in 2007. The seminar dealt with non-discrimination issues, and the panellists considered six case studies which involved nationality and residence, thin capitalization, branch taxation, corporate reorganization and group relief, and the tax sparing credit.

This article examines selected aspects of Australia's emerging "model" tax treaty which reflects the changes in its tax treaty policy. The article first summarizes the findings and recommendations of the Review of Business Taxation and the Review of International Taxation Agreements in respect of Australia's treaty policy. The article then discusses the changes in Australia's tax treaty policy. The article concludes that, going forward, Australia's "model" treaty will more closely resemble the OECD Model as Australia moves from being a capital importer to being a capital exporter.

This article gives an overview of Sarkozy's tax package introduced in August 2007 - the law in favour of labour, employment and purchasing power. The article discusses the major provisions of the tax package, including the tax exemption for overtime income, the mortgage interest tax credit, reform of the direct tax cap, and the substantial cuts in taxes on capital. The article also analyses the decision of France's Constitutional Court which upheld the direct tax cap, but struck down another provision of the tax package on grounds that it breached the principle of equality.

US subnational state tax regimes operate independently of, and often differently from, the US national tax regime. This article examines three recent developments in US state taxation that raise issues of international interest: (1) state court decisions sustaining corporate income tax jurisdiction over taxpayers without a permanent establishment or other physical presence in the state; (2) a state court decision limiting the dividends-received deduction for foreign subsidiaries to foreign subsidiaries that earn taxable income in the state, despite other state court decisions suggesting that such a provision is unconstitutionally discriminatory; and (3) the continuing evolution of the Streamlined Sales and Use Tax Agreement offering vendors simplified tax administration and relief from audit exposure in return for collecting taxes in all the states that have complied with the Agreement.