International Taxation
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Principles Of International Taxation
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Author : Angharad Miller
language : en
Publisher: A&C Black
Release Date : 2012-01-01
Principles Of International Taxation written by Angharad Miller and has been published by A&C Black this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-01-01 with Law categories.
This superb book will guide the reader through the key issues and practical aspects of international tax practice. It demonstrates how different global tax systems interact and how to prevent paying more tax than necessary. The basic principles of each aspect of international taxation are outlined and then examined in greater depth and detail. This updated third edition includes coverage of both UK and EU legislation and regulation, as well as the key cases and rulings. Complicated double taxation concepts are clearly illustrated with examples and diagrams to help the reader quickly understand how they'll apply in practice. Examples of policies adopted in other countries are included, along with specialist commentary and guidance.
International Taxation
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Author : Joseph Isenbergh
language : en
Publisher: Thomson West
Release Date : 2005
International Taxation written by Joseph Isenbergh and has been published by Thomson West this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Business & Economics categories.
International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index
The International Taxation System
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Author : Andrew Lymer
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-12-06
The International Taxation System written by Andrew Lymer and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-12-06 with Business & Economics categories.
International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Taxmann S International Taxation A Compendium 5 200 Pages 200 Experts 137 Articles 4 Volumes 4th Edition
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Author : The Chamber of Tax Consultants
language : en
Publisher: Taxmann Publications Private Limited
Release Date : 2021-02-10
Taxmann S International Taxation A Compendium 5 200 Pages 200 Experts 137 Articles 4 Volumes 4th Edition written by The Chamber of Tax Consultants and has been published by Taxmann Publications Private Limited this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-02-10 with Law categories.
CTC’s International Tax Compendium is a collection of incisive & in-depth articles on international taxation, which serves as a reference manual and indeed, a practice guide for its readers. The current edition of the compendium is more current, more incisive, covers a broader range of topics, and like its previous three editions, promises to be another very useful tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators ought to find this a useful reference point both for technical analysis as well as for understanding the right perspective in which to view some of the international tax developments of the recent past. This compendium will equip its readers with better knowledge and practical examples to be able to serve their clients better. The current edition of the compendium is a comprehensive four volumes set, containing approximately 5,200+ pages covering all major topics on the subject of International Taxation, such as: • Amendments made in the Income-tax Act, 1961 • Changes introduced in the OECD Model Tax Convention, 2017 • Updates introduced in the OECD Model Commentary in 2017 • Updates introduced in UN Model Tax Convention in 2017 • Global Focus on combating Tax Evasion • Initiation of various Anti Avoidance Measure and tightening of Anti Money Laundering Laws • Implementation of Multilateral Instruments pursuant to the publication of the BEPS Action Plan Reports in October, 2015. The Present Publications is the 4th Edition, covering 137 Articles authored by 200+ Experts. This Compendium is a balanced collection of articles by recognised experts in the field, by young as well as eminent professionals and also by experienced and knowledgeable Commissioners of Income-tax & Senior Ex- Revenue Officials. This book is divided into four volumes, and their contents (volume-wise) are listed below: • Volume 1 & 2 contains articles explaining the following: 𝚘 Theme/basic concepts of Double Tax Avoidance Agreements 𝚘 Various Articles of Model Tax Convention 𝚘 Specific provisions of the Domestic Law dealing with the Taxation of Non-Residents and Cross-Border Transactions • Volume 3 contains industry specific articles such as: 𝚘 Taxation of Telecom Sector 𝚘 Broadcasting & Telecasting industries 𝚘 Electronic Commerce 𝚘 Foreign Banks, Offshore Funds, FII’s etc. • Volume 4 contains articles on the following: 𝚘 FEMA and other Domestic Laws such as Prevention of Money Laundering Act, Foreign Contribution Regulation Act, Black Money Act, Benami Law 𝚘 Various Anti-Avoidance Measures & other specialised articles
International Taxation Of Permanent Establishments
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Author : Michael Kobetsky
language : en
Publisher: Cambridge University Press
Release Date : 2011-09-15
International Taxation Of Permanent Establishments written by Michael Kobetsky and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-09-15 with Law categories.
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
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.
International Taxation In A Nutshell
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Author : Richard L. Doernberg
language : en
Publisher: West Publishing Company
Release Date : 2001
International Taxation In A Nutshell written by Richard L. Doernberg and has been published by West Publishing Company this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001 with Business & Economics categories.
After an introduction to the fundamentals of U.S. international taxation, the U.S. activities of foreign taxpayers and the foreign activities of U.S. citizens and residents are addressed. Special U.S. international tax provisions creating incentives and disincentives for certain conducts or forms of business transactions are looked at and the effect of U.S. transfer taxes (estate, gift and generation-skipping tax) on both resident and nonresident aliens is dealt with.
Fixing U S International Taxation
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Author : Daniel N. Shaviro
language : en
Publisher: Oxford University Press
Release Date : 2014-04
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 2014-04 with Law categories.
Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Principles Of International Taxation
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Author : Lynne Oats
language : en
Publisher: Bloomsbury Publishing
Release Date : 2021-09-30
Principles Of International Taxation written by Lynne Oats and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-09-30 with Business & Economics categories.
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
International Tax Primer
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Author : Brian J. Arnold
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-01-14
International Tax Primer written by Brian J. Arnold 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 2019-01-14 with Law categories.
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.