Transfer Tax Payment And Apportionment
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Transfer Tax Payment And Apportionment
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Author : Jeffrey N. Pennell
language : en
Publisher:
Release Date :
Transfer Tax Payment And Apportionment written by Jeffrey N. Pennell and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Apportionment categories.
... is a study of the law concerning the payment and apportionment of federal and state wealth transfer taxes. The portfolio discusses both federal and state law and examines the interplay of those rules with the tax payment provisions contained in wills and other estate planning instruments. The portfolio is designed principally for estate planners, for trust and estate fiduciaries and their counsel, and for lawyers and other professionals involved in both tax and nontax litigation concerning apportionment matters.
Treatment Of Intercompany Transfer Pricing For Tax Purposes
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Author : Yuichi Ikeda
language : en
Publisher: International Monetary Fund
Release Date : 1992-09-01
Treatment Of Intercompany Transfer Pricing For Tax Purposes written by Yuichi Ikeda and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992-09-01 with Business & Economics categories.
Tax authorities in several countries have intensified their surveillance of intercompany transfer pricing in recent years. This paper examines the legislative and administrative issues related to the treatment of intercompany transfer pricing for tax purposes. It reviews the existing international guidelines and national rules on methods for determining appropriate transfer prices, as well as the issues related to tax administration practices for the implementation of those rules. Various systems, proposed or introduced to improve the predictability of taxation, are also examined. This paper further reviews the recent discussions on the “commensurate-with-income” standard and the pricing methodologies proposed thereunder. It finally reviews some alternative approaches to international income allocation which are proposed or adopted in lieu of the transfer pricing approach.
Basis Of Assets
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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date :
Basis Of Assets written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with categories.
Federal Estate And Gift Taxes A Proposal For Integration And For Correlation With The Income Tax
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Author : United States. Department of the Treasury. Advisory Committee on Estate and Gift Taxation
language : en
Publisher:
Release Date : 1948
Federal Estate And Gift Taxes A Proposal For Integration And For Correlation With The Income Tax written by United States. Department of the Treasury. Advisory Committee on Estate and Gift Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1948 with Inheritance and transfer tax categories.
Revenue Revisions 1947 48
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Author : United States. Congress. House. Committee on Ways and Means
language : en
Publisher:
Release Date : 1947
Revenue Revisions 1947 48 written by United States. Congress. House. Committee on Ways and Means and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1947 with Taxation categories.
Continuation of hearings on proposed changes to administrative provisions of the Revenue Code. Focuses on the taxation of farmers cooperatives, pt.4; Includes "Federal Estate and Gift Taxes. A Proposal for Integration and for Correlation with Income Tax," Advisory Committee to Treas Dept on Estate and Gift Taxation (p. 3798-3973), pt.5.
Federal Transfer Taxes
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Author : United States
language : en
Publisher:
Release Date : 2003
Federal Transfer Taxes written by United States and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003 with Inheritance and transfer tax categories.
Federal Taxes On Gratuitous Transfers Law And Planning
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Author : Joseph M. Dodge
language : en
Publisher: Aspen Publishing
Release Date : 2023-01-31
Federal Taxes On Gratuitous Transfers Law And Planning written by Joseph M. Dodge and has been published by Aspen Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-01-31 with Law categories.
Federal Taxes on Gratuitous Transfers: Law and Planning, Second Edition is a sophisticated Estate & Gift Tax casebook with plenty of problems, nuance, and policy discussion. The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. This book deals primarily with the federal wealth transfer taxes, and with the federal income tax as it bears on gratuitous transfers. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. The book includes relevant case law and references to statutes and regulations and has many explanations and problems to help students new to the field to find a way through this complicated material. The book is appropriate for both J.D. and LL.M. courses in Estate and Gift Tax. New to the 2nd Edition: All material up to date with current law and current exemption amounts (as of 2023) All new chapter on estate and gift tax issues for individuals who are noncitizens or nonresidents Income taxation of trusts and estates material moved to stand-alone chapter Raises issues of race, gender, sexual orientation, and other identity taxes, making it easier for students to connect doctrine and policy Discussion of policy debate around long-term and perpetual trusts Lists, illustrations and photographs provide engaging visual commentary Sidebars on relevant persons, places, and things provide interesting content, surprising those who think that tax is a dry and boring subject Professors and students will benefit from: Emphasis on text, statutes, and regulations, rather than cases. “Building block” organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students. High-profile authorship: Joseph M. Dodge and Wendy C. Gerzog are distinguished emeriti faculty. Bridget J. Crawford, Jennifer Bird-Pollan, and Victoria J. Haneman are all well-established in the field and are attuned to the needs of today’s students. Reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. More emphasis on valuation and use of FLPs than in other books; valuation is introduced early on and integrated with other material. Relation of tax doctrine to tax planning strategies. Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake. Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems
The Allocation Of Multinational Business Income Reassessing The Formulary Apportionment Option
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Author : Richard Krever
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-02-20
The Allocation Of Multinational Business Income Reassessing The Formulary Apportionment Option written by Richard Krever 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 2020-02-20 with Law categories.
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
Internal Revenue Acts Of The United States 1909 1950
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Author : Bernard D. Reams (Jr.)
language : en
Publisher:
Release Date : 1979
Internal Revenue Acts Of The United States 1909 1950 written by Bernard D. Reams (Jr.) and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1979 with Taxation categories.
Tax Management Estates Gifts And Trusts Journal
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Author :
language : en
Publisher:
Release Date : 2004
Tax Management Estates Gifts And Trusts Journal written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with Gifts categories.