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ARTICLES
In Defence of the European Court of Justice
Prof. Dr Frans Vanistendael
pp. 90-99
This article is the basis for the Graduation Lecture (Maarten J. Ellis Lecture) delivered by Prof. Frans Vanistendael on 30 August 2007 at the International Tax Center Leiden (LLM Program in International Taxation) at the University of Leiden, the Netherlands.
In Defence of the European Court of Justice - Response to Frans Vanistendael
Prof. Maarten J. Ellis
pp. 99-100
This article is the response of Prof. Maarten Ellis to the Graduation Lecture (Maarten J. Ellis Lecture) delivered by Prof. Frans Vanistendael on 30 August 2007 at the International Tax Center Leiden (LLM Program in International Taxation) at the University of Leiden, the Netherlands.
SUBJECT
Fifth Protocol to the Canada-United States Tax Treaty
Nathan Boidman and Michael Kandev
pp. 101-115
In September 2007, Canada and the United States signed the long-awaited fifth protocol to the 1980 Canada-United States tax treaty. The changes made by the protocol are generally relieving in nature and were widely anticipated, but some of the changes are adverse to taxpayers and come as a surprise. This article discusses the principal changes made by the fifth protocol, focusing on matters relevant to cross-border business enterprises in light of the current issues and outstanding matters which remained after the substantial changes made by the protocols in 1995 and 1997.
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Sometimes Even Nothing Can Be Taxable in South Africa
Ernest Mazansky
pp. 116-121
This article examines the recent decision of the Supreme Court of Appeal of South Africa in the Brummeria case in relation to tax arising on an interest-free loan. The article discusses the facts of the case, the legislative and judicial background, and the Court's judgement. The article also considers some of the criticisms of the judgement and its effect.
Rationalizing EU Taxation of Commercial Motor Fuel: Harmonized Rates versus Apportionment - Technological Considerations
Charles E. McLure, Jr.
pp. 121-128
This article is the second in a two-part series. It examines the technologies that might be used to implement an apportionment-based system of taxing commercial fuel and/or road user charges: approaches that record all the distance travelled in a country and systems that collect tolls on high-speed motorways. This article concludes that once interoperable satellite-based technology has been introduced throughout the EU, it may be possible to rely on that technology to produce the records needed to apportion motor fuel on the basis of the distance travelled in each Member State.
CUMULATIVE INDEX
p. 115
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