United States Tax Treatment for “Foreign Sales Corporations”
- 최초 등록일
- 2012.06.25
- 최종 저작일
- 2011.11
- 12페이지/
한컴오피스
- 가격 1,500원
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소개글
영어로 외국 무역분쟁 사례 WTO홈페이지에서 발췌한 후 저의 의견 작성한 것입니다.
목차
Introduction:
Summary of this dispute
Supplementary Explanation about FSC
Conclusion
References
본문내용
Introduction: revolved around the reason why I study this case
I`m interested in finance and bank, and I read an article about Lone Star recently. Lone star sold the Korea Exchange Bank to the Hana Financial Group, and would have reaped a 4.5 billion-dollar profit from that deal. However, the Lone Star don`t need to pay taxes because of double tax avoidance agreement. The birthplace of an international income is different from the registration area of an international fund or company. In that case, double tax is unreasonable. The purpose of double tax avoidance agreement is to avoid double taxes. I think that tax avoidance of Lone Star should be regulated.
I want to investigate dispute case similar to Lone Star`s case, and the US-FSC is most similar to Lone Star`s case. Therefore, I selected the US-FSC case.
Summary of this dispute
1. On 18 November 1997, the EC requested consultations with the US in respect of Sections 921-927 of the US Internal Revenue Code and related measures, establishing special tax treatment for “Foreign Sales Corporations” (FSC). The EC contended that these provisions were inconsistent with US obligations under Articles III:4 and XVI of the GATT 1994, Articles 3.1(a) and (b) of the Subsidies Agreement, and Articles 3 and 8 of the Agreement on Agriculture.
참고 자료
이충녕(연세대학교), 국회도서관, 2008, WTO/DSB 판정 불이행에 관한 연구 :`대항조치`와 `위반조치의 철회`를 중심으로
http://www.wto.org - dispute settlement
Request for Consultation
Panel Report
Appellate Body Report
Article 21.5 Panel Report
Article 21.5 Appellate Body Report
Recourse to Article 22.6 Arbitration Report
Second Recourse to Article 21.5 Panel Report
Second Recourse to Article 21.5 Appellate Body Report
Agriculture: Art. 1, 3, 8, 9, 10
Subsidies and Countervailing Measures: Art. 1.1, 3.1(a), 3.1(b)
GATT 1994: Art. III:4
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