Download or read book Advance Income Tax Rulings and Technical Interpretations written by and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Advance Tax Rulings in Perspective written by Benjamin Alarie and published by . This book was released on 2015 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are an increasingly common feature of mature income tax systems throughout the world. The Organisation for Economic Co-operation and Development's (OECD's) work demonstrates that there has been a trend from 1990 to 2013 among OECD member countries to adopt advance tax rulings regimes. The international expansion of advance tax rulings seems both intuitively desirable and salutary. Upon deeper reflection, both theoretically and empirically, however, there is a puzzle. Why are advance tax rulings regimes so popular?This article makes two contributions to our understanding of advance tax rulings. The first contribution is to highlight that the increased pervasiveness of advance tax rulings internationally is potentially puzzling in the light of Givati's analysis, which suggests that the balance of strategic considerations facing taxpayers systematically disfavours taxpayers seeking advance tax rulings. Theory thus appears - at least as a preliminary matter - to be out of step with the observed rulings practices tracked by the OECD. We then consider how to resolve the puzzling popularity of advance tax rulings. We find the increased pervasiveness of advance tax rulings regimes should not be entirely surprising despite the apparent conflict with economic theory.To complement the arguments from theory, we offer some tentative evidence that advance tax rulings may not be of any consequence economically speaking. Empirical analyses of panel data of rulings practices published by the OECD do not show any reliable correlations of observed practice with social or economic fundamentals. This finding is consistent with the puzzle posed by economic theory, which suggests that rulings regimes are not likely to be particularly important in practice. This can arise in part due to the relatively slow process for issuing advance rulings compared to the timeframe facing taxpayers to make key business decisions. From an optimistic perspective, advance tax rulings are best regarded as serving an expressive function in support of the rule of law and sound tax administration. Less generously, a cynic might be tempted to say that the resolution to the puzzle posed by the incongruence between theory and practice may be that the best reason to have a binding rulings regime may be because just about everyone else has one.
Download or read book Introducing an Advance Tax Ruling ATR Regime written by Mr.Christophe J Waerzeggers and published by International Monetary Fund. This book was released on 2016-05-31 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Download or read book Advance Tax Rulings and Principles of Law written by Carlo Romano (juriste).) and published by IBFD. This book was released on 2002 with total page 579 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.
Download or read book Countering Harmful Tax Practices More Effectively Taking Into Account Transparency and Substance Action 5 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015-10-12 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.
Download or read book Understanding Income Tax Problems written by Chiasson, Gilles and published by Don Mills, Ont. : R. de Boo. This book was released on 1988 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Download or read book Statement of Procedural Rules written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Income Tax Treatment of Cooperatives Handling of losses written by Donald A. Frederick and published by . This book was released on 1993 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Canada U S Tax Treaty written by and published by . This book was released on 1981 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Introducing a General Anti Avoidance Rule GAAR written by Mr.Christophe J Waerzeggers and published by International Monetary Fund. This book was released on 2016-01-31 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax avoidance continues to attract attention globally with strong support for tax law reform at all levels. This Tax Law IMF Technical Note focuses on some of the key design and drafting considerations of one specific legal instrument (being, a statutory general anti-avoidance rule (GAAR)) which is often considered by authorities to combat unacceptable tax avoidance practices. A GAAR is typically designed to strike down those otherwise lawful practices that are found to be carried out in a manner which undermines the intention of the tax law such as where a taxpayer has misused or abused that law. However, the objective of combating unacceptable tax avoidance can itself make the legal design of a GAAR complex. This is simply because the phrase “tax avoidance” means different things to different people. Whatever the form of a GAAR, it should give effect to a policy that seeks to strike down blatant, artificial or contrived arrangements which are tax driven. However, the GAAR should be designed and applied so as not to inhibit or impede ordinary commercial transactions. This Tax Law IMF Technical Note discusses and explores how drawing a line between those arrangements which should be caught by the GAAR is a matter of degree and can be delicate.
Download or read book Managing Income Tax Compliance through Self Assessment written by Andrew Okello and published by International Monetary Fund. This book was released on 2014-03-11 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern tax administrations seek to optimize tax collections while minimizing administration costs and taxpayer compliance costs. Experience shows that voluntary compliance is best achieved through a system of self-assessment. Many tax administrations have introduced self-assessment principles in the income tax law but the legal authority is not being consistently applied. They continue to rely heavily on “desk” auditing a majority of tax returns, while risk management practices remain largely underdeveloped and/or underutilized. There is also plenty of opportunity in many countries to enhance the design and delivery of client-focused taxpayer service programs, and better engage with the private sector and other stakeholders.
Download or read book Uniform Issue List written by and published by . This book was released on 1986 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Your Federal Income Tax for Individuals written by United States. Internal Revenue Service and published by . This book was released on 1996 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
