Fixing U S International Taxation
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Fixing U S International Taxation
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Author : Daniel N. Shaviro
language : en
Publisher: Oxford University Press
Release Date : 2014-01-08
Fixing U S International Taxation written by Daniel N. Shaviro and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-01-08 with Law categories.
International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
Reform Of U S International Taxation
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Author : Jane G. Gravelle
language : en
Publisher: DIANE Publishing
Release Date : 2011-04
Reform Of U S International Taxation written by Jane G. Gravelle and has been published by DIANE Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-04 with Reference categories.
Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? Contents of this report: The Current System and Possible Revisions; Neutrality, Efficiency, and Competitiveness; Assessing the Existing Tax System; Territorial Taxation: The Dividend Exemption Proposal; A Residence-Based System in Practice; President Obama's Proposals to Restrict Deferral and Cross-Crediting; Tax Havens: Issues and Policy Options; General Reforms of the Corporate Tax and Implications for International Tax Treatment. Charts and tables. This is a print on demand edition of an important, hard-to-find publication.
Introduction To U S International Taxation
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Author : Paul R. McDaniel
language : en
Publisher: Springer
Release Date : 1981-06-17
Introduction To U S International Taxation written by Paul R. McDaniel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1981-06-17 with Business & Economics categories.
This book presents the basic priciples and rules of the United States international tax system in a relatively brief form. The purpose is to provide an overview of the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work or carry on a trade or business in the US or abroad.
Introduction To United States International Taxation
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Author : James R. Repetti
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-07-07
Introduction To United States International Taxation written by James R. Repetti 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 2021-07-07 with Law categories.
The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
Reform Of U S International Taxation
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Author : David Brumbaugh
language : en
Publisher:
Release Date : 2007
Reform Of U S International Taxation written by David Brumbaugh and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Investments, Foreign categories.
A striking feature of the modern U.S. economy is its growing openness--its increased integration with the rest of the world. The attention of tax policymakers has recently been focused on the growing participation of U.S. firms in the international economy and the increased pressure that engagement places on the U.S. system for taxing overseas business. Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? The current U.S. system for taxing international business is a hybrid. In part the system is based on a residence principle, applying U.S. taxes on a worldwide basis to U.S. firms while granting foreign tax credits to alleviate double taxation. The system, however, also permits U.S. firms to defer foreign-source income indefinitely -a feature that approaches a territorial tax jurisdiction. In keeping with its mixed structure, the system produces a patchwork of economic effects that depend on the location of foreign investment and the circumstances of the firm. Broadly, the system poses a tax incentive to invest in countries with low-tax rates of their own and a disincentive to invest in high-tax countries. In theory, U.S. investment should be skewed towards low-tax countries and away from high-tax locations. Evaluations of the current tax system vary, and so do prescriptions for reform. According to traditional economic analysis, world economic welfare is maximized by a system that applies the same tax burden to prospective (marginal) foreign and domestic investment so that taxes do not distort investment decisions. Such a system possesses "capital export neutrality," and could be accomplished by worldwide taxation applied to all foreign operations along with an unlimited foreign tax credit. In contrast, a system that maximizes national welfare-a system possessing "national neutrality"--Would impose a higher tax burden on foreign investment, thus permitting an overall disincentive for foreign investment. Such a system would impose worldwide taxation, but would permit only a deduction, and not a credit, for foreign taxes. A tax system based on territorial taxation would exempt overseas business investment from U.S. tax. In recent years, several proponents of territorial taxation have argued that changes in the world economy have rendered traditional prescriptions for international taxation obsolete, and instead prescribe territorial taxation as a means of maximizing both world and national economic welfare. For such a system to be neutral, however, capital would have to be completely immobile across locations. A case might be made that such a system is superior to the current hybrid system, but it is not clear that it is superior to other reforms, including not only a movement toward worldwide taxation by ending deferral, but also restricting deductions for costs associated with deferred income or restricting deferral and foreign tax credits for tax havens. This report will not be updated
Fundamentals Of International Taxation
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Author : Boris I. Bittker
language : en
Publisher:
Release Date : 1991
Fundamentals Of International Taxation written by Boris I. Bittker and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1991 with Aliens categories.
Advanced Introduction To International Tax Law
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Edward Elgar Publishing
Release Date : 2019
Advanced Introduction To International Tax Law written by Reuven S. Avi-Yonah and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Double taxation categories.
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
Introduction To United States International Taxation
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Author : Paul McDaniel
language : en
Publisher: Springer
Release Date : 1998-02-25
Introduction To United States International Taxation written by Paul McDaniel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-02-25 with Business & Economics categories.
Tax practitioners outside the United States whose clients have activities in the country generally rely on their U.S. tax advisors for technical advice on the U.S. tax aspects of their clients' transactions. In order to position themselves to evaluate the advice received and to relate it to their own tax systems, however, foreign tax advisors must place the material they receive from their U.S. counterparts within the overall structure of the U.S. international tax system. Introduction to United States International Taxation provides the structural framework within which a U.S. tax problem can be placed. Now in its fourth edition, this reliable resource presents the basic principles and rules of the U.S. international tax system in a concise, manageable form. Without becoming mired in technical detail, The book provides an overview of the principles adopted by the United States in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the United States or abroad. The inclusion of or reference to many key primary source documents enhances the usefulness of Introduction to United States International Taxation. These include: Internal Revenue Code provisions under discussion the more important Treasury Regulations issued interpreting the statutory rules significant administrative announcements of the Internal Revenue Service (Revenue Rulings and Revenue Procedures) illustrative principal cases
International Taxation
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Author : Joseph Isenbergh
language : en
Publisher: Aspen Publishers
Release Date : 1990
International Taxation written by Joseph Isenbergh and has been published by Aspen Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with Business & Economics categories.
Comprehensive guide on the tax consequences of inbound transactions.
International Taxation
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Author : Philip F. Postlewaite
language : en
Publisher:
Release Date : 1995
International Taxation written by Philip F. Postlewaite and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1995 with Aliens categories.