Limit search to available items
Book Cover
E-book
Author Ammendola, Giuseppe

Title From Creditor to Debtor : the U.S. Pursuit of Foreign Capital - the Case of the Repeal of the Withholding Tax
Published Milton : Routledge, 2018

Copies

Description 1 online resource (294 pages)
Series Routledge Library Editions: Taxation Ser. ; v. 2
Routledge Library Editions: Taxation Ser
Contents Cover; Half Title; Title Page; Copyright Page; Table of Contents; Acknowledgments; Preface; Tables; Charts; ABBREVIATIONS; I. Introduction; A: PURPOSE AND METHODOLOGY OF THE RESEARCH; 1. The Repeal and Policy Analysis; 2. Relationship to Political Science and International Political Economy; 3. The Eurocurrency and Eurobond Markets: Basic Terminology; B: GENERAL BACKGROUND ON THE EUROBOND MARKET; 1. Origins; 2. The Eurobond Market and the International Finance Subsidiaries: General Features; 3. U.S. Companies' Use of the Eurobond Market; II. Initiation: the Road to the Hearing
A: PROBLEM RECOGNITION1. Taxes and the Eurobond Market; 2. The Repeal of the Withholding Tax; 3. The U.S.-Netherlands Antilles Tax Treaty: The Investor's Use of the Treaty; 4. The Borrower's Use of the Treaty; 5. The Internal Revenue Service Position; 6. Exceptions to the Thirty Percent Tax on Interest Other Than Those Originating from Tax Treaty; 7. Tax Treaty Exemptions; B. GENERATION OF ALTERNATIVES; 1. Proposals Previous to the 98th Congress; 2. Proposals Considered by the 98th Congress; 3. The Proposals Before Congress on April 11, 1984; 4. Congress's Options
III. Estimation: Congress Looks at the AlternativesA. THE MAY 1984 HEARING: AN ANALYTICAL SUMMARY; 1. The Government Witnesses; 2. Transnational Interest Groups; 3. Domestic Interest Groups; 4. Summing Up the Main Interest Groups' Position; 5. The Differences between the 1984 and the 1976 Hearings; IV. Selection: Congress Approves the Repeal; A. THE REPEAL OF THE THIRTY PERCENT TAX ON INTEREST PAID TO FOREIGNERS; 1. Scope of the Legislation; 2. The Repeal and the Secretary; V. Implementation: The Complex World of Treasury Regulations; A. TREASURY REGULATIONS: COMPLIANCE AND TAX EVASION
B. BEARER DEBT: SEC REGULATIONS CONGRESSIONAL CONCERNS AND THE FEDERAL GOVERNMENT DEFICIT; 1. The SEC Regulations; 2. Congressional Concern and the Federal Government Deficit; C. FURTHER REGULATORY LIMITATIONS TO THE SCOPE OF THE REPEAL LEGISLATION: "REGISTRATION-REQUIRED OBLIGATIONS"; D. THE IRS REVENUE RULINGS OF OCTOBER 15, 1984: THE CONTINUATION OF THE UNCERTAINTY OVER U.S. CORPORATIONS' USE OF THE NETHERLANDS ANTILLES; E. THE REPEAL LEGISLATION AND ITS IMPLEMENTATION: SUMMING UP; F. MORE RECENT DEVELOPMENTS; G. TREASURY AND CRISIS DECISION-MAKING
1. The Events Leading to the Summer of 1987 Crisis2. The NA Treaty Termination: A Ten Days' Crisis; 3. The Crisis under Analytical Scrutiny; VI. Evaluation: The Impact of the Repeal; A. THE NEED FOR CAPITAL; 1. The Federal Debt; 2. The Corporate and Household Debt; B. THE U.S. BALANCE OF PAYMENTS AND INVESTMENT POSITION; 1. Macro-economic Policy Coordination; 2. The Years after the End of the Bretton Woods System; 3. Cooperation and the Repeal; C. THE U.S. NET INVESTMENT POSITION; D. THE UNITED STATES AS A DEBTOR NATION; E.U.S. ATTITUDES TOWARD FOREIGN INVESTMENT
Notes F. THE POINT OF VIEW OF THE FOREIGN INVESTOR
Print version record
Subject Investments, Foreign -- Taxation -- United States
Interest -- Taxation -- United States
Withholding tax -- United States
Debts, Public -- United States
Debts, Public
Interest -- Taxation
Investments, Foreign -- Taxation
Withholding tax
United States
Form Electronic book
ISBN 9781351116886
1351116886
9781351116893
1351116894
9781351116879
1351116878
9781351116909
1351116908