Download or read book Corporate Residence written by David Hughes and published by A&C Black. This book was released on 2013-01-01 with total page 303 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is about the UK's approach to determining the residence status of corporations and thus their exposure to UK tax. If companies are not managed and controlled in the correct way, they could unintentionally become UK resident and so be rendered subject to UK taxes. The question of where a company is actually resident has become increasingly significant, with the international nature of so many business transactions today, including e-commerce transactions. Table of Contents include: The Importance of UK Residence Status * The Incorporation Rule * Central Management and Control (The Case Law Test) * FA 1994 S249 and the Impact of Tax Treaties on the Determination of Residence * Place of Effective Management * HMRC Practice * The Application of the Case Law Test to Subsidiaries * Peripatetic Boards * UK Coordination Centers * The Implications of Modern Forms of Communication * Directors Located in the UK and Overseas * Outside Interference: Shadow Directors, and other Outsiders * Conclusion

Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

Download or read book Corporate Residence and International Taxation written by Robert Couzin and published by IBFD. This book was released on 2002 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.

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 Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law written by Savvas Kostikidis and published by Kluwer Law International B.V.. This book was released on 2024-10-10 with total page 473 pages. Available in PDF, EPUB and Kindle. Book excerpt: Series on International Taxation Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law It is well known that multinational corporations establish foreign subsidiaries in great measure to reduce their worldwide tax burden. This groundbreaking book examines the content of the substance requirement in double tax convention residence rules, transfer pricing rules, anti-abuse rules, and controlled foreign corporation rules in the context of international and EU tax law, disentangling the complex relationship between the substance requirements in these four sets of legal rules. Following a descriptive-analytic method, for each substance requirement of the four sets of legal rules, the discussion deals with the content of economic substance in complex scenarios, for example: holding companies; special purpose vehicles; loss-making subsidiaries; subsidiaries with management in more than one state; subsidiaries managed by the parent company; outsourcing; and subsidiaries ‘borrowing’ the substance of other group companies. The author introduces a new method of assessment of substance requirements, offering practical solutions for their uniform application in international and European tax law. In its thorough examination of how substance requirements work and how they are interrelated among different sets of tax rules, this book has no peers. It will be welcomed by taxation practitioners and corporate counsel in Europe and worldwide.

Download or read book Residence of Companies Under Tax Treaties and EC Law written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2009 with total page 969 pages. Available in PDF, EPUB and Kindle. Book excerpt: Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.

Download or read book Self employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Global Perspectives on E Commerce Taxation Law written by Subhajit Basu and published by Ashgate Publishing, Ltd.. This book was released on 2007 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field.

Download or read book Corporate Tax Residence and Mobility written by Edoardo Traversa and published by . This book was released on 2018 with total page 764 pages. Available in PDF, EPUB and Kindle. Book excerpt: The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject resident corporate taxpayers to full tax liability, usually on a worldwide basis. In tax treaties, residence plays a fundamental role in the allocation of taxing powers between states. Moreover, within the European Union, it gives access to the legal protection granted to companies by internal market rules, whether contained in EU treaties (fundamental freedoms) or in tax directives. Today, however, the globalization and the digitalization of the economy are putting residence under heavy pressure. Within multinational enterprises, the geographical dislocation of the functions performed by people and entities within the multinational group makes it harder to identify a central place of decision or management in cases where this place is not the same as the place where the company was incorporated. Moreover, tax planning strategies involving location or the transfer of residence to low-tax jurisdictions have come under the spotlight of international organizations, such as the OECD and the European Union. Against this background, this book examines the notion of residence from a comparative, EU and international law perspective. It is divided into two parts. Part one comprises a general introductory report, as well as five thematic reports on key present and future issues concerning the tax residence of companies. Part two comprises the national reports of 14 EU Member States and 6 non-EU Member States (Norway, Russia, Serbia, Turkey, Ukraine and the United States). Those reports contain an extensive analysis of the definition and function of corporate tax residence on the basis of a questionnaire (which is included as an appendix in this book). With contributions from renowned academics from Europe and beyond, this book offers an insightful and multifaceted perspective on a fundamental concept of domestic and international taxation.

Download or read book CDC Yellow Book 2020 written by Centers for Disease Control and Prevention (CDC) and published by . This book was released on 2019 with total page 721 pages. Available in PDF, EPUB and Kindle. Book excerpt: The definitive reference for travel medicine, updated for 2020 "A beloved travel must-have for the intrepid wanderer." -Publishers Weekly "A truly excellent and comprehensive resource." -Journal of Hospital Infection The CDC Yellow Book offers everything travelers and healthcare providers need to know for safe and healthy travel abroad. This 2020 edition includes: � Country-specific risk guidelines for yellow fever and malaria, including expert recommendations and 26 detailed, country-level maps � Detailed maps showing distribution of travel-related illnesses, including dengue, Japanese encephalitis, meningococcal meningitis, and schistosomiasis � Guidelines for self-treating common travel conditions, including altitude illness, jet lag, motion sickness, and travelers' diarrhea � Expert guidance on food and drink precautions to avoid illness, plus water-disinfection techniques for travel to remote destinations � Specialized guidelines for non-leisure travelers, study abroad, work-related travel, and travel to mass gatherings � Advice on medical tourism, complementary and integrative health approaches, and counterfeit drugs � Updated guidance for pre-travel consultations � Advice for obtaining healthcare abroad, including guidance on different types of travel insurance � Health insights around 15 popular tourist destinations and itineraries � Recommendations for traveling with infants and children � Advising travelers with specific needs, including those with chronic medical conditions or weakened immune systems, health care workers, humanitarian aid workers, long-term travelers and expatriates, and last-minute travelers � Considerations for newly arrived adoptees, immigrants, and refugees Long the most trusted book of its kind, the CDC Yellow Book is an essential resource in an ever-changing field -- and an ever-changing world.

Download or read book Commentaries on the Law of Private Corporations written by Seymour Dwight Thompson and published by . This book was released on 1915 with total page 1060 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements Action 2 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2017-07-27 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).

Download or read book Guerrilla Tacos written by Wesley Avila and published by Ten Speed Press. This book was released on 2017-10-10 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: The definitive word on tacos from native Angeleno Wes Avila, who draws on his Mexican heritage as well as his time in the kitchens of some of the world's best restaurants to create taco perfection. In a town overrun with taco trucks, Wes Avila's Guerrilla Tacos has managed to win almost every accolade there is, from being crowned Best Taco Truck by LA Weekly to being called one of the best things to eat in Los Angeles by legendary food critic Jonathan Gold. Avila's approach stands out in a crowded field because it's unique: the 50 base recipes in this book are grounded in authenticity but never tied down to tradition. Wes uses ingredients like kurobata sausage and sea urchin, but his bestselling taco is made from the humble sweet potato. From basic building blocks to how to balance flavor and texture, with comic-inspired illustrations and stories throughout, Guerrilla Tacos is the final word on tacos from the streets of L.A.

Download or read book The American Corporation Cases written by Thomas Foster Withrow and published by . This book was released on 1881 with total page 718 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book A Summary of the Law of Private Corporations written by Leslie Jay Tompkins and published by . This book was released on 1904 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Lawyers Reports Annotated written by and published by . This book was released on 1913 with total page 1258 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Lawyers Reports Annotated written by and published by . This book was released on 1897 with total page 936 pages. Available in PDF, EPUB and Kindle. Book excerpt: