Download or read book The Attribution of Profits to Permanent Establishments written by Raffaele Russo and published by IBFD. This book was released on 2005 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016

Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Download or read book EC Tax Review written by and published by . This book was released on 2002 with total page 728 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Courts and Tax Treaty Law written by Guglielmo Maisto and published by IBFD. This book was released on 2007 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.

Download or read book Martindale Hubbell International Law Directory written by Martindale-Hubbell (Firm) and published by . This book was released on 2003-04 with total page 3004 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Taxation and Development A Comparative Study written by Karen B. Brown and published by Springer. This book was released on 2017-01-16 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.

Download or read book Our Selfish Tax Laws written by Anthony C. Infanti and published by MIT Press. This book was released on 2018-10-02 with total page 253 pages. Available in PDF, EPUB and Kindle. Book excerpt: Why tax law is not just a pocketbook issue but a reflection of what and whom we, as a society, value. Most of us think of tax as a pocketbook issue: how much we owe, how much we'll get back, how much we can deduct. In Our Selfish Tax Laws, Anthony Infanti takes a broader view, considering not just how taxes affect us individually but how the tax system reflects our culture and society. He finds that American tax laws validate and benefit those who already possess power and privilege while starkly reflecting the lines of difference and discrimination in American society based on race, ethnicity, socioeconomic class, gender, sexual orientation and gender identity, immigration status, and disability. Infanti argues that instead of focusing our tax reform discussions on which loopholes to close or which deductions to allow, we should consider how to make our tax system reflect American ideals of inclusivity rather than institutionalizing exclusion. After describing the theoretical and intellectual underpinnings of his argument, Infanti offers two comparative case studies, examining the treatment of housing tax expenditures and the unit of taxation in the United States, Canada, France, and Spain to show how tax law reflects its social and cultural context. Then, drawing on his own work and that of other critical tax scholars, Infanti explains how the discourse surrounding tax reform masks the many ways that the American tax system rewards and reifies privilege. To counter this, Infanti urges us to work together to create a society with a tax system that respects and values all Americans.

Download or read book Commitment to Equity Handbook written by Nora Lustig and published by Brookings Institution Press. This book was released on 2023-05-01 with total page 1437 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Nora Lustig, the Commitment to Equity Handbook: Estimating the Impact of Fiscal Policy on Inequality and Poverty (Brookings Institution Press and CEQ Institute-Tulane University, 2nd edition, 2022) is a unique manual on the theory and practical methods to estimate the impact of taxation and public spending on inequality and poverty. In addition, the second edition covers frontier topics such as alternative approaches to measure the redistributive effect of education, health, and infrastructure spending. Policymakers, social planners, and economists are provided with a step-by-step guide to applying fiscal incidence analysis, illustrated by country studies. The 2nd edition of the Handbook has two volumes. Volume 1 is comprised of Part I, Methodology, describes what a CEQ Assessment© is and presents the theoretical underpinnings of fiscal incidence analysis and the indicators used to assess the distributive impact and effectiveness of fiscal policy. Part II, Implementation, presents the methodology on how taxes, subsidies, and social spending should be allocated. It includes a step-by step guide to completing the CEQ Master Workbook©, a multi-sheet Excel file that houses detailed information on the country’s fiscal system and the results used as inputs for policy discussions, academic papers, and policy reports. Part III, “Applications,” presents applications of the CEQ framework to low- and middle-income countries and includes simulations of policy reforms. In this 2nd edition, chapters 1, 6, and 8 have been significantly updated and two new country studies have been added to Part III. Parts IV (updated), V (new), and VI (new) are available online only. Part IV contains the CEQ Assessment’s main tools. Part V includes the databases housed in the CEQ Data Center on Fiscal Redistribution. Part VI contains the CEQ Institute’s microsimulation tools. Volume 2 (new) includes a collection of chapters whose purpose is to expand the knowledge and methodological frontiers to sharpen even further the analysis of fiscal policy’s redistributive impact. Topics include: alternative approaches to value in-kind education and health services; alternative methods to evaluate spending on infrastructure; corporate taxes and taxation on capital incomes; inter-temporal fiscal incidence and the redistributive consequences of social insurance pensions; fiscal redistribution, macroeconomic stability and growth; and, the political economy of fiscal redistribution.

Download or read book Tierra Vacante en Ciudades Latinoamericanas written by Nora Clichevsky and published by . This book was released on 2002 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Vacant urban land--the product of land market activity, the actions of private agents, and the policies of public agents--is an important challenge for policy makers. Vacant lots on the urban fringe and in central and interstitial areas have affected growth patterns in Latin America. Contributors to this book analyze the problems and opportunities related to vacant urban land in five cities: Buenos Aires, Argentina; Rio de Janeiro, Brazil; Quito, Ecuador; Lima, Perú; and San Salvador, El Salvador.

Download or read book The World s Leading Lawyers 2000 2001 written by and published by . This book was released on 2000 with total page 1358 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Bulletin for International Fiscal Documentation written by and published by . This book was released on 2002 with total page 724 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Spanish Fiscal Transition written by Sara Torregrosa Hetland and published by Springer Nature. This book was released on 2021-09-18 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an analysis of the process and outcomes of the tax reform, with a focus on progressivity, redistribution, and inequality. Between 1977 and 1986, Spain underwent a comprehensive tax reform which shaped its fiscal system until today. It was made in connection with the transition to democracy and indeed was understood as a fundamental part of the political change. The book situates the reform both within Spanish history and international trends in tax systems and connects it to the expansion of the welfare state and regional decentralization in Spain. The analysis reveals that the tax system failed to attain progressivity, and significant levels of fraud had a noticeable impact on inequality. Because of this, fiscal redistribution remained limited. In the new political economy of the second globalization, late democratic and fiscal transitioners were unable to emulate the path of the welfare state forerunners.

Download or read book Integrated Coastal Zone Management of Coral Reefs written by Kent Gustavson and published by World Bank Publications. This book was released on 2000 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The applied research indicates that, to improve awareness, park education programs should be targeted specifically to the user groups primarily through outreach programs. Further, the Park's management programs should be highlighted, particularly the beneficial, tangible products and services (benefits) the Park provides to each user group... The closer the tie between reef conditions and business earnings, the greater the users' support for reef conservation." Coral reefs are sometimes referred to as "canaries of the sea" because of their early warning ability to show near-shore oceanic stress. Because of their biological diversity, they are also called "rainforests of the sea." Coral reefs are vital to the well being of millions of people. Coral reef managers and government officials trying to save their valuable national resources have turned to research on coral reefs for help. The research presented in this publication merits a great deal of notice because the output is useful for decision support and training tools in integrated coastal zone management (ICZM). The work on cost-effectiveness analysis has developed integrated economic and ecological models, relying extensively on fuzzy logic procedures to model impacts and effects of interventions within the reef environment. By contrast, the marine system valuation work provides economic valuations of coral reefs, demonstrating the use of different modeling methods and treating key policy issues within this context. This publication will interest coastal zone experts and managers worldwide

Download or read book Global Investment Competitiveness Report 2017 2018 written by World Bank Group and published by World Bank Publications. This book was released on 2017-10-25 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Global Investment Competitiveness report presents new insights and evidence on drivers of foreign direct investment (FDI) in developing countries, and FDI’s role in development. The report’s survey of 750 executives of multinational corporations finds that a business-friendly legal and regulatory environment is a key driver of investment decisions in developing countries, along with political stability, security, and macroeconomic conditions. The report’s topic-specific chapters explore the potential of FDI to create new growth opportunities for local firms, assess the power of tax holidays and other fiscal incentives to attract FDI, analyze characteristics of FDI originating in developing countries, and examine the experience of foreign investors in countries affected by conflict and fragility. Three key features of this Global Investment Competitiveness report distinguish it from other publications on FDI. First, its insights are based on a combination of first-hand perspectives of investors, extensive analysis of available data and evidence, and international good practices in investment policy design and implementation. Secondly, rather than exploring broad FDI trends, the report provides detailed and unique analysis of FDI depending on its motivation, sector, geographic origin and destination, and phase of investment. Thirdly, the report offers practical and actionable recommendations to policymakers in developing countries wishing to reform their business climates for increased investment competitiveness. As such, the report is meant to complement other knowledge products of the World Bank Group focused even more explicitly on country-level data, detailed reform diagnostics, and presentation of best practices. We are confident this report will bring value and fresh perspectives to a variety of audiences. To governments and policymakers, including investment promotion professionals, the report offers direct insights into the role of government policies and actions in investors’ decision-making. To foreign investors and site location consultants, the report provides information on FDI trends and drivers across sectors and geographies. For academic audiences, the new datasets on investment incentives and FDI motivations enables opportunities for additional research and analysis. Lastly, for development assistance providers and other stakeholders, the report highlights key approaches for maximizing FDI’s benefits for development.

Download or read book RETRACTED BOOK 151 Trading Strategies written by Zura Kakushadze and published by Springer. This book was released on 2018-12-13 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides detailed descriptions, including more than 550 mathematical formulas, for more than 150 trading strategies across a host of asset classes and trading styles. These include stocks, options, fixed income, futures, ETFs, indexes, commodities, foreign exchange, convertibles, structured assets, volatility, real estate, distressed assets, cash, cryptocurrencies, weather, energy, inflation, global macro, infrastructure, and tax arbitrage. Some strategies are based on machine learning algorithms such as artificial neural networks, Bayes, and k-nearest neighbors. The book also includes source code for illustrating out-of-sample backtesting, around 2,000 bibliographic references, and more than 900 glossary, acronym and math definitions. The presentation is intended to be descriptive and pedagogical and of particular interest to finance practitioners, traders, researchers, academics, and business school and finance program students.

Download or read book Medical and Dental Expenses written by and published by . This book was released on 1990 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt: