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CONTENTS

Christian, Ernest S., Jr., Patton, Boggs & Blow, on behalf of the Com-

mittee on State Taxation, Council of State Chambers of Commerce,

Washington, D.C___.

Cory, Kenneth, controller, State of California, Sacramento, Calif.

De Looze, Theodore W., chief tax counsel, Oregon Department of
Justice, Salem, Oreg-.

Denebeim, Bruce E., senior vice president, the Chartered Bank of Lon-
don, San Francisco, Calif__

Gallagher, Sterling, commissioner, department of revenue, State of
Alaska, Juneau, Alaska----

Gotelli, Andrew W., Peat, Marwick, Mitchell & Company, on behalf
of California Council for International Trade, San Francisco, Calif__

Hayakawa, Hon. S. I., a U.S. Senator from California....

Kurtz, Hon. Jerome, Commissioner, Internal Revenue Service; ac-

companied by Stuart Seigel, Chief Counsel, Internal Revenue

Service

Lobdell, John J., director of revenue, State of Oregon; immediate past

chairman of the board of trustees of the Federation of Tax Admin-

istrators; and present chairman of the Multi-State Tax Commission,

Boulder, Colo---

90

149

295

146

236

291

184

Osterhuis, Paul J., legislation counsel, Joint Committee on Taxation;

accompanied by David Brockway, legislation attorney, Joint Com-

mittee on Taxation_‒‒

Philion, Norman J., executive vice president, Air Transport Association
of America; accompanied by John Krimsky, Jr., vice president, Pan
American World Airways, Washington, D.C., and James T. O'Hara,
special counsel to the Air Transport Association of America, Jones,
Day, Reavis and Pogue, Washington, D.C--

56

Reveal, Ernest I., president, R. T. French Co., Rochester, N.Y.
Smith, Daniel G., president, National Association of Tax Administra-
tors, Chicago, Ill.

206

63

Walker, Charles M., former Assistant Secretary of the Treasury for
Tax Policy__.

221

Woodworth, Laurence N., Assistant Secretary for Tax Policy, Depart-
ment of the Treasury; accompanied by Mr. David Foster, tax con-
sultant, Department of the Treasury, and Mr. Charles Kingson,
International Tax Counsel, Department of the Treasury--.

48, 82

Insertions for the record:

Letter to Senator Frank Church from Laurence N. Woodworth, De- Page partment of the Treasury, dated July 18, 1977-

Letter to Senator John Sparkman from Representative Al Ullman, dated July 18, 1977.

Letter to United Kingdom Petroleum Revenue Tax, Frederic W. Hick-
man, Assistant Secretary for Tax Policy, from Lawrence B. Gibbs,
Department of the Treasury, dated July 28, 1975_.
Adoption of unitary apportionment systems---

Prepared statement of Assistant Secretary of the Treasury Laurence
N. Woodworth_.

Prepared statement of Paul Oosterhuis, legislation counsel, and David
Brockway, legislation attorney, Joint Committee on Taxation----
Prepared statement of Norman J. Philion, Air Transport Association
of America__

Prepared statement of the National Association of Tax Administra-
tors, Daniel G. Smith, president and attachments_-_.

Prepared statement of John J. Lobdell, director of revenue, State of
Oregon

Prepared statement of Assistant Secretary of the Treasury Laurence
N. Woodworth_.

2

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State of California Franchise Tax Board, United States-United Kingdom Treaty Position Paper--

Prepared statement of Sterling Gallagher, commissioner of revenue,
State of Alaska--

Multistate Tax Commission Resolution No. 2-Opposing Federal restrictions on State taxing powers and methods..

Supreme Court of Montana decision in Montana Department of Revenue, State of Montana, Petitioner and Appellant, v. The American Smelting and Refining Co., Defendant and Respondent, No. 13249, 1977

Prepared statement of Oregon Department of Revenue, presented by
Theodore W. De Looze, chief of tax counsel, Oregon Department
of Justice---

Prepared statement of Ernest S. Christian, Jr., on behalf of Committee
on State Taxation, Council of State Chambers of Commerce_-
Supplemental letter to Senator John Sparkman from Ernest S.
Christian, Jr., dated August 3, 1977___.

152

159

174

181

Prepared statement of John S. Nolan, on behalf of the British National Committee of the International Chamber of Commerce and the Confederation of British Industry

188

Prepared statement of Ernest I. Reveal, president, R. T. French Co., and attachment_-_.

209

Position paper of Valentine Brookes, Esq., on proposed United StatesUnited Kingdom Income Tax Convention, particular reference to limitation of the power of the States to tax

215

Extension of testimony of Valentine Brookes, Esq--

219

Prepared statement of Charles M. Walker, former Assistant Secretary of the Treasury for Tax Policy---.

225

Supplemental letter to Senator John Sparkman from Charles M.
Walker, dated July 29, 1977---

232

Corporations represented on the California Council for International
Trade through Corporate and Individual Memberships----
Prepared statement of Carl A. Stutsman, Jr., Esq---

236

243

Prepared statement of Paul S. Berger, general counsel, Screen Actors
Guild AFL-CIO, and attachment_

249

Prepared statement of Bruce K. Denebeim_

298

Memorandum on issues raised in testimony before the Senate Committee on Foreign Relations in connection with the proposed Income Tax Treaty with the United Kingdom, supplied by the Department of Treasury-.

303

Letter to Senator Frank Church from Kenneth Cory, controller of the
State of California, dated September 9, 1977, in response to Treas-
ury Department memorandum____

312

Appendix:
"Brown Asks Change in Business Tax-Revisions Could Bring Auto,
Electronics Plants to State," article by Jerry Gilman, the Los
Angeles Times, July 15, 1977-

Technical explanation of the Convention Between the Government
of the United States of America and the Government of the United
Kingdom of Great Britain and Northern Ireland for the avoidance
of double taxation and the prevention of fiscal evasion with respect
to income and capital gains--.
Technical explanation of the Convention Between the Government
of the United States of America and the Government of the Re-
public of the Philippines for the avoidance of double taxation and
the prevention of fiscal evasion with respect to taxes on income---.
Letter to Senator Jacob K. Javits from Laurence N. Woodworth,
Assistant Secretary for Tax Policy, Department of the Treasury,
dated March 1, 1977-

Memorandum to the Senate Foreign Relations Committee from Harry
G. Gonrevitch, senior specialist in taxation and fiscal policy, Con-
gressional Research Service, the Library of Congress, dated June 6,
1977
Technical explanation of the Convention Between the United States
of America and the Republic of Korea for the avoidance of double
taxation and the prevention of fiscal evasion with respect to taxes on
income and the encouragement of international trade and invest-
ment.

Page

317

318

350

375

378

381

Text of telegram to Senator John Sparkman from Hon. Edmund G.
Brown, Jr., Governor of California, and Senator Alan Cranston of
California, dated September 27, 1977----

399

Letter to Senator James A. McClure from Hon. John V. Evans, Governor of Idaho, dated May 2, 1977___

399

Letter to Senator James A. McClure from Hon. Cecil D. Andrus,
Governor of Idaho, dated June 16, 1976-----

401

Statement of Arthur C. Roemer, commissioner of revenue, State of
Minnesota

402

Letter to Senator John Sparkman from Hon. Ray Blanton, Governor of Tennessee, dated June 21, 1977---

Letter to Senator John Sparkman from Senator Patrick J. Leary,
dated July 22, 1977, enclosing a letter to Senator Leary from Hon.
Richard A. Snelling, Governor of Vermont, dated June 23, 1977----
Letter to Senator John Sparkman from Hon. Mills E. Godwin, Jr.,
Governor of Virginia, dated July 5, 1977-

403

404

404

Prepared statement of Marry Ellen McCaffree, Washington Director of Revenue

405

Letter to Senator Robert C. Byrd from Hon. John D. Rockefeller IV,
Governor of West Virginia, dated July 7, 1977_.

407

Letter to Senator Robert C. Byrd from Richard L. Dailey, State tax
commissioner of West Virginia, dated April 12, 1976___.
Letter to Senator John Sparkman from Warren J. Sinsheimer, deputy
chief executive, the Plessey Co., Ltd., dated July 21, 1977, and en-
closed statement

408

409

"Brown [Governor] Defends Stand," article from the Wall Street Journal, July 12, 1977---

411

Letter to Mr. Martin Huff, exectuive officer, California Franchise Tax
Board, from Hon. W. Michael Blumenthal, Secretary of the Treasury,
dated February 15, 1977----

Statement submitted by the Committee on State Taxation, Council of
State Chambers of Commerce_.

Statement submitted on behalf of the Barclays Bank of California___
Statement submitted by the Emergency Committee for American
Trade

Letter from I. E. Zacher, director, corporate taxes and insurance,
Heinz World Headquarters, dated July 22, 1977, enclosing United
Kingdom House of Commons debate prior to ratification of United
States-United Kingdom tax treaty..

412

412

414

424

427

Letter to Senator John Sparkman from Norman J. Philion, Air Trans-

port Association of America, dated August 2, 1977, enclosing text of

telegrams submitted to Laurence N. Woodworth, Assistant Secre-

tary for Tax Policy, Department of the Treasury, and summary

memorandum

Letter to Senator John Sparkman from Richard M. Hammer, president,

U.S.A. Branch, International Fiscal Association, Inc., dated July 28,

1977, and enclosed statement_

Statement by Emergency Committee for American Trade_

Statement of the National Foreign Trade Council, Inc--

Letter to Senator John Sparkman from Charles Stewart, president,

Machinery and Allied Products Institute, dated July 11, 1977-----

Letter to Mr. Martin Huff, Executive Officer, California Franchise Tax

Board, from Hon. W. Michael Blumenthal, Secretary of the Treas-

ury, dated February 15, 1977.

Letter to Senator Jacob Javits from W. K. Woodson, corporate tax
manager, Getty Oil Co., dated July 29, 1977, enclosing excerpts from
a hearing of the State of California Franchise Tax Board, July 12,
1977

Resolution unanimously adopted at the 45th annual meeting of the Na-

tional Association of Tax Administrators, held in Williamsburg, Va.,

May 30-June 3, 1977__.

Exchange of correspondence between Senator Frank Church and the

Honorable Jerome Kurtz, Commissioner of Internal Revenue, in Oc-

tober 1977, concerning IRS review of OPEC tax rulings.

Letter to John Sparkman from Kenneth Cory, controller of the State
of California, dated August 2, 1977, enclosing material on the over-

all economic impact of United States-United Kingdom Tax Treaty

provisions

490

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