Download or read book Controlled Foreign Corporations as Fiscally Transparent Entities written by Daniele Canè and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated at treaty level, which would also serve to avoid undesirable policy effects. The legal framework of tax treaties, as integrated by the Multilateral Convention (MLI), is now ready to support such a coordinated application of CFC rules. The new set of provisions for transparent entities can be used to this end, on the assumption that certain CFCs should also be treated as transparent entities. Indeed, CFC rules patterned after the transparency approach produce effects and involve problems comparable to transparent partnerships. This article elaborates on some of these problems and illustrates how the new provisions dedicated to transparent entities interact with each other and allow a balanced application of treaties to CFCs as well.Full-text Paper.

Download or read book Controlled Foreign Corporations as Fiscally Transparent Entities the Application of CFC Rules in Tax Treaties written by D. Canè and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated at treaty level, which would also serve to avoid undesirable policy effects. The legal framework of tax treaties, as integrated by the Multilateral Convention (MLI), is now ready to support such a coordinated application of CFC rules. The new set of provisions for transparent entities can be used to this end, on the assumption that certain CFCs should also be treated as transparent entities. Indeed, CFC rules patterned after the transparency approach produce effects and involve problems comparable to transparent partnerships. This article elaborates on some of these problems and illustrates how the new provisions dedicated to transparent entities interact with each other and allow a balanced application of treaties to CFCs as well.

Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.

Download or read book Tax Law Design and Drafting Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Download or read book Tax Planning for Domestic and Foreign Partnerships LLCs Joint Ventures and Other Strategic Alliances written by and published by . This book was released on 2003 with total page 1050 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation written by Joseph Isenbergh and published by CCH. This book was released on 2006 with total page 806 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules Action 3 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.

Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.

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 Introduction to U S Income Tax written by Joseph Amico and published by Springer. This book was released on 1993-08-16 with total page 276 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains in plain language the complexity of the US tax system, often by comparison and contrast with European and other national tax systems. Topics covered include individual and corporate income taxes, partnership taxation, special types of taxpayers (pensions, Subchapter S-corporations) and the underlying "unwritten law" of US taxation. Special emphasis is placed on international rules, particularly inbound business, sales and investment. Broad coverage is given to anti-avoidance rules which contribute to the US tax system's complexity (e.g. Subpart F, FIRPTA and transfer pricing).

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

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 Tax Withholding and Estimated Tax written by and published by . This book was released on 1993 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Taxation of Foreign Investment in U S Real Estate written by United States. Department of the Treasury and published by . This book was released on 1979 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Employment Law Review written by Erika C Collins and published by Law Business Research Ltd.. This book was released on 2017-04-07 with total page 1263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK

Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

Download or read book Circular A Agricultural Employer s Tax Guide written by and published by . This book was released on 1992 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: