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The Meaning of ‘Enterprise,’ ‘Business,’ and ‘Business Profits’ under Tax Treaties and Domestic Tax Law: U.S. Report


Allison Christians


McGill University - Faculty of Law

Yariv Brauner


University of Florida - Fredric G. Levin College of Law

June 8, 2011

Allison Christians, Yariv Brauner, THE MEANING OF ‘ENTERPRISE,’ ‘BUSINESS,’ AND ‘BUSINESS PROFITS,’ UNDER TAX TREATIES AND DOMESTIC TAX LAW, 2011
Univ. of Wisconsin Legal Studies Research Paper No. 1161

Abstract:     
The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are often ill-defined and under-theorized, especially in their interaction with other regulatory areas. This U.S. Report, commissioned for a comparative volume on the subject, focuses on the use and significance of these concepts from a U.S. perspective. Part I deals with the meaning of these concepts under domestic non-tax legislation, with a particular focus on private law, commercial law, company law and bankruptcy law. Part II describes the concepts under domestic tax law with reference to relevant jurisprudence, administrative practice and doctrine. Part III discusses the concepts as interpreted for purposes of double tax conventions, with reference to specific treaty provisions, case law and literature. Part IV discusses the compatibility of domestic law provisions with their use in tax conventions and concludes.

Number of Pages in PDF File: 29

Keywords: taxation, international tax, business, business profits, enterprise, tax convention, tax treaty, interpretation, jurisprudence, OECD

JEL Classification: H20, H24, H25, K34

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Date posted: June 10, 2011 ; Last revised: August 1, 2011

Suggested Citation

Christians, Allison and Brauner, Yariv, The Meaning of ‘Enterprise,’ ‘Business,’ and ‘Business Profits’ under Tax Treaties and Domestic Tax Law: U.S. Report (June 8, 2011). Allison Christians, Yariv Brauner, THE MEANING OF ‘ENTERPRISE,’ ‘BUSINESS,’ AND ‘BUSINESS PROFITS,’ UNDER TAX TREATIES AND DOMESTIC TAX LAW, 2011; Univ. of Wisconsin Legal Studies Research Paper No. 1161. Available at SSRN: http://ssrn.com/abstract=1860344 or http://dx.doi.org/10.2139/ssrn.1860344

Contact Information

Allison Christians (Contact Author)
McGill University - Faculty of Law ( email )
1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada
Yariv Brauner
University of Florida - Fredric G. Levin College of Law ( email )
P.O. Box 117625
Gainesville, FL 32611-7625
United States
3522730949 (Phone)
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