Interpretation And Application Of Tax Treaties In North America
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Interpretation And Application Of Tax Treaties In North America
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Author : Juan Angel Becerra
language : en
Publisher: IBFD
Release Date : 2007
Interpretation And Application Of Tax Treaties In North America written by Juan Angel Becerra and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Canada categories.
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Interpretation And Application Of Tax Treaties
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Author : Ned Shelton
language : en
Publisher: Bloomsbury Professional
Release Date : 2004-01-01
Interpretation And Application Of Tax Treaties written by Ned Shelton and has been published by Bloomsbury Professional this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-01-01 with Business & Economics categories.
"This book provides an excellent, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Other highlights include case studies and OECD model treaties. Written by an expert in the field and taking the practical approach rather than the academic, this truly is an essential global tool for the tax adviser wishing to use tax treaties in tax planning."
The Meaning Of Enterprise Business And Business Profits Under Tax Treaties And Eu Tax Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2011
The Meaning Of Enterprise Business And Business Profits Under Tax Treaties And Eu Tax Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Double taxation categories.
The Meaning of "Enterprise", "Business" and "Business Profits" under Tax Treaties and EU Tax Law, comprising the proceedings and working documents of an annual seminar held in Milan in November 2010, provides an in-depth analysis of the meaning of these three essential concepts in relevant tax treaties and law. The analysis starts from an EU tax law perspective, with a particular emphasis on the European Directives. The above concepts are then considered from domestic tax law viewpoints. The book then moves to tax treaty law. Most notably, an examination of the history and interpretation of the concepts of "enterprise", "business" and "business profits" is presented, starting from the works of the League of Nations to the current OECD Model Tax Convention. Next, specific tax treaty issues are considered. In particular, the controversial issues concerning the interpretation of the notions of "enterprise" and "enterprise of a Contracting State" are discussed. Also, the concepts of "profits" and "business profits" are thoroughly reviewed. The concept of "enterprise" in the context of the non-discrimination clause laid down by Art. 24 of the OECD Model Tax Convention is then examined. Individual country surveys provide an in-depth analysis of the aforementioned concepts and issues from a national viewpoint in selected European and North American jurisdictions, as well as in Australia and Japan. The book concludes with a round-table discussion among some of the most renowned international tax scholars on the desirability to change the OECD Model Tax Convention and its Commentaries. This book is essential reading for all those dealing with issues of taxation of enterprises engaged in cross-border activities and can be considered a new cornerstone in the subject matter."--Publisher's website
U S Income Tax Treaties
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Author : Richard L. Doernberg
language : en
Publisher:
Release Date : 1999
U S Income Tax Treaties written by Richard L. Doernberg and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999 with Double taxation categories.
Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Canada U S Tax Treaty
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Author : Fraser Milner Casgrain (Firm)
language : en
Publisher: CCH Canadian Limited
Release Date : 2009
Canada U S Tax Treaty written by Fraser Milner Casgrain (Firm) and has been published by CCH Canadian Limited this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Business & Economics categories.
United States Income Tax Treaties
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Author : Klaus Vogel
language : en
Publisher: Springer
Release Date : 1989
United States Income Tax Treaties written by Klaus Vogel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1989 with Law categories.
Comprehensive loose-leaf guide analysing United States income tax treaties. The commentary is divided into three parts providing general background information regarding income tax treaties and the model treaty process, commentary of the individual provisions of the US Model and of existing US treaties, appendices are included.
International Tax Policy And Double Tax Treaties
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Author : Kevin Holmes
language : en
Publisher: IBFD
Release Date : 2007
International Tax Policy And Double Tax Treaties written by Kevin Holmes and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Double taxation categories.
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
United States Estate And Gift Tax Treaties
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Author : Jeffrey A. Schoenblum
language : en
Publisher:
Release Date :
United States Estate And Gift Tax Treaties written by Jeffrey A. Schoenblum and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Decedents' estates categories.
... describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties to which the United States is a party, as well as the income tax treaty with Canada, which bears on U.S. transfer taxes as well as Canadian income tax at death. The portfolio is divided into six parts. Part I: Introduction, explains the purpose and types of transfer tax treaties. Part II: Situs-Type Treaties, describes when situs-type transfer tax treaties apply and explains how a situs-type treaty assigns primary taxing jurisdiction to one country. It also analyzes the effect that situs-type treaties have on the deductions and credits of treaty countries. Part III: Domicile-Type Treaties, describes when domicile-type treaties apply and how these treaties assign primary taxing jurisdiction. It also analyzes the situs rules that are incorporated into domicile-type treaties, the effect that domicile-type treaties have on the deductions, exemptions, and credits of treaty countries, and the general operation of the treaties' nondiscrimination provisions. Part IV: Special, Administrative, and Enforcement Provisions, discusses the ways in which transfer tax treaties enable a treaty country to enforce the collection of death taxes and exchange information with the other country, as well as issues that a taxpayer subject to a treaty may face in reporting income. Part V: Treaty Interpretation, sets forth the principles of treaty interpretation and construction. Part VI: Particular Treaty Analysis, discusses the details of each transfer tax treaty.
The Interpretation Of Income Tax Treaties With Particular Reference To The Commentaries On The Oecd Model
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Author :
language : en
Publisher:
Release Date : 2005-01-01
The Interpretation Of Income Tax Treaties With Particular Reference To The Commentaries On The Oecd Model written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005-01-01 with Double imposition - Conventions - Interprétation categories.
Fundamental Issues And Practical Problems In Tax Treaty Interpretation
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Author : Michael Schilcher
language : en
Publisher:
Release Date : 2008
Fundamental Issues And Practical Problems In Tax Treaty Interpretation written by Michael Schilcher and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Conflict of laws categories.
This volume deals in Part I with general principles of tax treaty interpretation, including many general issues of international law and especially treaty law. Part II is dedicated to specific tax treaty provisions that trigger particularly interesting interpretation questions. Part III is concerned with situations in which states disagree on the interpretation of tax treaties.