Corporate Form & International Taxation of Box Corporations

Corporate Form & International Taxation of Box Corporations
Studia Juridica Stockholmiensia 87

By Roland Dahlman
November 2006
Stockholm University
Distributed by
ISBN: 9185445347
536 pages, 6½ x 9½"
$129.50 Paper Original

Abstract:
During three archaeological excavation campaigns in the Garrison area of Birka, unique evidence of Viking Age military material culture was uncovered. Numerous finds show evidence of links between the Birka warriors and the Eastern trade route. The cultural exchange that took place along this route influenced both weaponry and dress, creating a stylistic expression described in archaeological research as oriental, oriental-style or orient-influenced. The nomadic mounted warrior of the Eastern steppes was a major influence, and the Garrison material indicates direct contact, exemplified by a complete belt-set of steppe nomadic origin. This paper focuses on the variety of oriental-sytle mounts found in the Garrison that had originally served as mounts on the costume and equipment of the nomad rider where they functioned as symbos of rank and status. The study shows that the Birka warriors were aware of the original intrinsic meaning and symbolism of the Eastern mounted warrior's dress, belt and belt-pouch and to an extent adopted the ideological framework associated with these.

Contents:
Introduction, subject of the thesis, public reaction to the Box
     Corporation, purpose, methodology and limitations
Contextual matters and overlapping phenomena: the Base, Conduit and Box
     Corporation, international tax law principles and the legal institution of the corporation
Analysis of a principle of tax neutrality in connection with the
     phenomenon of the Box Corporation
Analysis of a tax theory of the Box Corporation: legal security and efficient taxation
Jurisdiction to tax and demarcation of international taxing rights among different jurisdictions
Analysis of a methodology for international tax planning using the
     Box Corporation and the corporate direct foreign investment alternative
Investigation of circular and hovering corporate ownership of the
     Box Corporation and resulting tax consequences
Swedish foreign-entity classification and the creation of a foreign tax subject
The intermediary holding company and ownership and control criteria of the Box Corporation
Analysis of the relationship between sheltering of foreign income and CFC tax provisions
Analysis of the possible impact of tax treaty terms on the
     efficient and predictable tax treatment of the Box Corporation
Analysis of international exchange of information, mutual administrative assistance procedures
     and domestic national disclosure requirements of reportable transactions with the Box Corporation
Summary concluding remarks and recommendations

Business Law
International Business - Taxation

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