Suchergebnisse

In May 1960, it was announced that coffee export quotas, amounting to 7, 600, 000 BAGS of 132 pounds each, and adding 1, 302, 040 bags to the previously agreed annual quotas totaling 32, 650, 000 bags, had been fixed for the second quarter of 1960 by the directors of the International Coffee Agreement. For the full year, export quotas for eleven members had been revised upward, under a provision of the Agreement tying exports to the production estimates of the United States Department of Agriculture. Under the current revision, Brazil had been granted the largest quota —4, 139, 000 bags—and Colombia, the second largest—1, 417, 000 bags—each being permitted to export more than the quotas assigned, should the world market require more coffee.

In May 1960, it was announced that coffee export quotas, amounting to 7, 600, 000 bags of 132 pounds each, and adding 1, 302, 040 bags to the previously agreed annual quotas totaling 32, 650, 000 bags, had been fixed for the second quarter of 1960 by the directors of the International Coffee Agreement. For the full year, export quotas for eleven members had been revised upward, under a provision of the Agreement tying exports to the production estimates of the United States Department of Agriculture. Under the current revision, Brazil had been granted the largest quota —4, 139, 000 bags—and Colombia, the second largest—1, 417, 000 bags—each being permitted to export more than the quota assigned, should the world market require more coffee.

The twenty meetings of the 35th session of the Council of the International Civil Aviation Organization (ICAO) were held between November 12 and December 17, 1958, except for the first meeting which was called during the committee phase on September 25. At its last meeting the Council unanimously decided to appoint Mr. R. M. McDonnell of Canada, Secretary General of ICAO to succeed Carl Ljungberg of Sweden, who had served in that post for more than seven years. Additional elections and appointments, inter alia, included: W. G. Algar of Ireland, First Vice- President of the Council for 1958–1959; Col. E. Chagas of Brazil, Second Vice-President; Henry Soderberg of Sweden, Third Vice-President; J. R. Belcher of Canada, Chairman of the Finance Committee.

On December 17, 1948, a Committee of Naval Experts was appointed by the International Court of Justice to report on eight technical points involved in the Corfu Channel case. Under the order of the Court the Committee, whose members were Commodore J. Bull of the Royal Norwegian Navy, Commodore S. A. Forshell of the Royal Swedish Navy and Lt. Commander S. J. W. Elfferich of the Royal Netherlands Navy, was to submit a report on the situation in the north Corfu strait at the time the incident took place, the type of mines involved, the possibility of laying mines without the knowledge of Albania, and the technical possibilities involved in testimony of a witness for the United Kingdom, former Lt. Commander Kovacic of the Yugoslav navy.

On November 5, 1948, the International Court of Justice began oral hearings on the merits of the Corfu Channel case between Albania and the United Kingdom. By a decision on March 25, 1948, the Court had affirmed its competence in the case, and the following day had fixed time-limits for the subsequent pleadings; the last document of the written procedure, the Albanian rejoinder, had been filed with the Court on September 20, 1948. For the oral pleadings Professor B. Ecer of Czechoslovakia acted as judge ad hoc chosen by the Albanian government, replacing Judge Igor Daxner who was ill. Counsel for the United Kingdom were Sir Hartley Shawcross, Sir Eric Beckett, and Sir Frank Soskice, while Kahreman Ylli, Pierre Cot, and Joë Nordmann represented the Albanian government.

Because of the importance of technological innovation to economic growth, nations strive to stimulate and attract the research and development ("R&D") that leads to that innovation and to make themselves hospitable environments for the holding of intellectual property ("IP"). Tax policies have taken center stage in their efforts to accomplish these goals and to capture a share of the income from technological innovations. Designing cost-effective methods of supporting technological innovations has, however, become substantially more difficult as the world economy has become more interconnected. Where R&D is performed and where income is earned change in response to the nature and level of government support. The capacity of multinational enterprises ("MNEs") to shift their IP production, IP ownership, and IP income across national borders, along with their ability to establish new corporations in tax-favorable jurisdictions, makes designing cost-effective incentives exceptionally difficult. Devising appropriate tax rules for developing IP and for taxing IP income has become the central challenge for international income taxation. This Article examines the three primary tax policies supporting innovation: (1) incentives for R&D, (2) "patent boxes," and (3) tax benefits for "advanced manufacturing." It then briefly describes common techniques MNEs use to lower their taxes on IP income. The Article then assesses the various incentives and offers recommendations about how the United States might respond to challenges it now faces in promoting technological innovation. Based on extensive examination of the economic evidence, the Article concludes that, at most, only R&D incentives are justified. This Article also summarizes the current proposals for limiting opportunities for U.S. MNEs to shift IP income to low- or zero-tax jurisdictions. In that connection, it offers proposals for change that would more closely align U.S. taxes with U.S. sales.

Die Einkünftequalifikation bei Personengesellschaften erfolgt im deutschen Steuerrecht grundsätzlich tätigkeitsbezogen. Etwas anderes gilt jedoch gem. § 15 Abs. 3 Nr. 2 EStG für gewerblich geprägte Personengesellschaften: Deren Einkünfte stellen kraft Fiktion solche aus Gewerbebetrieb dar, auch wenn die zugrunde liegende Tätigkeit vermögensverwaltender Natur ist. -- Sebastian Leidel geht der Frage nach, welche Rolle diese »gewerbliche Prägung« im Internationalen Steuerrecht spielt. Er kommt u.a. zu dem Ergebnis, dass sie nicht dem Anwendungsbereich der isolierenden Betrachtungsweise (§ 49 Abs. 2 EStG) unterliegt. Unter Berücksichtigung ausgewählter Doppelbesteuerungsabkommen zeigt er ferner auf, dass die entsprechenden Einkünfte keine Unternehmensgewinne i. S. d. Art. 7 OECD-MA darstellen. Schließlich nimmt er kritisch zu der Neuregelung des § 50i EStG Stellung und legt dar, warum sie nicht in die geltende Gesetzessystematik passt. / »The ›Deemed Commercial Partnership‹ in International Tax Law« -- Under German tax law, a deemed commercial partnership generates income from trade or business by fiction of law. The author analyses the relevance of this fiction in international tax law, in particular within the scope of double taxation treaties.

I have mixed feelings about participating in this symposium as the feminist voice. On the one hand, I want to support the symposium editors' attempt to broaden the standard categories of international legal methodologies by including feminism in this undertaking. On the other hand, I am conscious of the limits of my analysis and its unrepresentativeness—the particularity of my nationality, race, class, sexuality, education and profession shapes my outlook and ideas on international law. I clearly cannot speak for all women participants in and observers of the international legal system. I also hope that one day I will stop being positioned always as a feminist and will qualify as a fully fledged international lawyer. My reservations are also more general because presenting feminism as one of seven rival methodological traditions may give a false sense of its nature. The symposium editors' memorandum to the participants encouraged a certain competitiveness: we were asked, "Why is your method better than others?" I cannot answer this question. I do not see feminist methods as ready alternatives to any of the other methods represented in this symposium. Feminist methods emphasize conversations and dialogue rather than the production of a single, triumphant truth.1 They will not lead to neat "legal" answers because they are challenging the very categories of "law" and "nonlaw." Feminist methods seek to expose and question the limited bases of international law's claim to objectivity and impartiality and insist on the importance of gender relations as a category of analysis. The term "gender" here refers to the social construction of differences between women and men and ideas of "femininity" and "masculinity"—the excess cultural baggage associated with biological sex.