Electronic commerce by its very innovative nature has engendered a novel application of past precedents. In the application of concepts of cross border taxation, it embraces traditional questions of source and resident taxation. Initially these principles were developed domestically. What has transpired in the development has been an evolution of the Due Process and commerce clauses of the United States. This evolution of constitutional considerations resulted because electronic commerce made for a complex determination of which domestic state had jurisdiction to tax electronic commerce. It brushed up against precedent notions of how the Due Process and Commerce Clause had been analyzed in terms of activities sourced and effects upon those whose borders are crossed. Keywords: ECommerce, Taxation, Commerce Clause, Due Process, Trade or Business, Permanent Establishment, Treaty.
This text is designed to establish an understanding of the fundamentals of currency. It provides a cursory overview of the international Monetary System of which currency is the core. To enhance the readers’ foundation, the second phase of the text provides an explanation of how and why the International Monetary Fund was established. That formation is tracked from initial formation of a fixed par value to our modern day system of floating exchange rates. With those fundamentals established, a presentation is provided to enable the reader to entertain the basic functioning of currency in the context of a global setting; the functioning of domestic international markets and external-Eurocurrency markets. That function process introduces sovereign and credit risks that accompany currency in the International Monetary System. A brief but concise presentation is provided to the reader to explain the source of these risks and the reason. Lastly, currency in itself has taxable transaction features. In a global setting it necessitates recognition of a means to manage those risks inherent in global trade, external currency markets, and capital investment. These facets are explained and documented. Keywords: Currency, Eurocurrency, IMF, Gold, Credit Risk, Sovereign Risk, Taxation of Financial Instruments, International Monetary System.
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