Global Perspectives On Income Taxation Law
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Global Perspectives On Income Taxation Law
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Author : Reuven Shlomo Avi-Yonah
language : en
Publisher: Oxford University Press, USA
Release Date : 2011
Global Perspectives On Income Taxation Law written by Reuven Shlomo Avi-Yonah and has been published by Oxford University Press, USA this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Law categories.
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
Global Perspectives On Income Taxation Law
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Author : Reuven Shlomo Avi-Yonah
language : en
Publisher:
Release Date : 2011
Global Perspectives On Income Taxation Law written by Reuven Shlomo Avi-Yonah and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Income tax categories.
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
Global Perspectives On E Commerce Taxation Law
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Author : Subhajit Basu
language : en
Publisher: Routledge
Release Date : 2016-04-22
Global Perspectives On E Commerce Taxation Law written by Subhajit Basu and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-22 with Business & Economics categories.
In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.
Comparative Fiscal Federalism
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-06-20
Comparative Fiscal Federalism written by Reuven S. Avi-Yonah and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-06-20 with Law categories.
Judicial review of taxation in the world’s two most economically significant multistate systems, the European Union and the United States, has exposed a remarkable divergence. Although there are important differences between the competences of the two tribunals, the fact remains that the European Court of Justice has been much more aggressive in striking down Member State income tax rules than has the United States Supreme Court in comparable cases. This book – the only full-scale comparative analysis of the tax jurisprudence of the two judicial systems, now in an updated second edition – asks: Why this divergence? And what can the two tribunals learn from each other about adjudicating issues that arise from the interaction of tax regimes in the context of a single market? Among the contributory issues and topics covered are the following: – conceptions of sovereignty and federalism; – discrimination in direct tax matters as an obstacle to a meaningful single market; – allocation of taxation competences; – nonresident versus resident taxation; – double burdens on cross-border economic activity; – retroactive recovery of unlawful state aid in the European Union; – role of competition law; – the revenue interests of states; – levels of corporate taxation; – the OECD Model’s nondiscrimination rules; and – the preliminary interpretation mechanism of the Court of Justice. An insightful and penetrating analysis of a topic of material importance to governments, tax policy makers, and tax lawyers on both sides of the Atlantic, this book clearly explains how the Supreme Court and the Court of Justice continue to struggle with the conflict between generally accepted tax principles and the effective prevention of discriminatory treatment of taxpayers. All tax professionals concerned with the interaction of sovereignty, tax assignment, legislation, and judicial decisions in tax law will benefit greatly from its clearsighted and comprehensive treatment, as well as from its perspectives on the practical implications of each tribunal’s decision making.
Taxation And Migration
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2015-08-21
Taxation And Migration written by Reuven S. Avi-Yonah and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-08-21 with Law categories.
Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base decisions. Nowhere is this necessity more pressing than in the development of relevant tax rules that meet the basic requirements of efficiency and equity. Moreover, the ascent of the so-called emerging economies coupled with the stagnation of the richest economies of the world implies reform of the current competition-based international tax regime and the adoption of a more cooperative paradigm. This important and timely book, for the first time in such depth, explores such aspects of the problem as the following: - migration for tax reasons, especially corporate "inversions" (change in corporate residence for tax purposes); - tax consequences related to individuals who receive free or subsidized education in one country and profit from it in another; - taxing cross-border retirement income; and - migration-related aspects of tax preferential treatment of the elderly. With particular emphasis on the effects and opportunities created by the changing international tax regime - and with attention to the role of tax treaties and recent court cases - chapters by well known tax experts present evidence on the consequences of migration in all its facets and simulate the effects of several recently enacted and proposed changes in tax law in European countries, the United States, and other jurisdictions. The grounded propositions and recommendations offered in this deeply informed book will allow policymakers to draft tax-residence rules that minimize distortion and promote fairness. The book will also be of interest to tax law practitioners and other tax specialists, migration experts, and academics investigating one of the crucial political issues of our time.
Non Discrimination In Tax Treaties
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Author : Pasquale Pistone
language : en
Publisher:
Release Date : 2016
Non Discrimination In Tax Treaties written by Pasquale Pistone and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016 with categories.
Recoge: 1: Nationality Non-Discrimination and Article 24 OECD Model: Perennial Issues, Recent Trends and New Approaches - 2: Non-Discrimination on the Basis of Nationality in IIAs: A Latin American Tax Perspective - 3: Interest Deduction Limitations: When To Apply Articles 9 and 24(4) of the OECD Model? - 4: Revisiting the Application of the Capital Ownership Non-Discrimination Provision in Tax Treaties - 5: Non-Discrimination in Tax Treaties – Art. 24(4) and (5) OECD MC: A Russian Approach to Tax Treaty Interpretation - 6: Non-Discrimination and Harmful Tax Competition under WTO Law and Article 24 of the OECD Model - 7: Non-Discrimination: Can the EU Learn from the OECD Model Convention and Vice Versa? - 8: Non-Discrimination à la Cour: The ECJ’s (Lack of) Comparability Analysis in Direct Tax Cases - 9: Discriminatory Taxation and the European Convention on Human Rights.
Global Perspectives Of An International Tax Lawyer
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Author : Mitchell Benedict Carroll
language : en
Publisher:
Release Date : 1978-01-01
Global Perspectives Of An International Tax Lawyer written by Mitchell Benedict Carroll and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1978-01-01 with Lawyers categories.
International Applications Of U S Income Tax Law
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Author : Ernest R. Larkins
language : en
Publisher: John Wiley & Sons
Release Date : 2003-11-20
International Applications Of U S Income Tax Law written by Ernest R. Larkins and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-11-20 with Business & Economics categories.
A clear, concise explanation of United States tax law’sinternational aspects In tackling a sometimes thorny set of laws and treaties,international tax expert Ernest Larkins emphasizes their economiceffects, showing how to avoid hazards while reaping rewards whichoften go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S.real estate, as well as the best structures for holding such realestate What a controlled foreign corporation is and what consequencesresult from this status Acceptable transfer pricing methods and what penalties applywhen taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law alsocontains many useful tools which allow readers to buildunderstanding through practice, as well as formulate and solve thecomplex problems international taxes can present. Order your copy today!
Jurisdiction To Tax Corporate Income Pursuant To The Presumptive Benefit Principle
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Author : Eva Escribano
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-10
Jurisdiction To Tax Corporate Income Pursuant To The Presumptive Benefit Principle written by Eva Escribano and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-05-10 with Law categories.
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Comparative Income Taxation
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Author : Hugh J. Ault
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-01-01
Comparative Income Taxation written by Hugh J. Ault and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-01-01 with Business & Economics categories.
The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.