Download or read book International Taxation Withholding written by Marnin J. Michaels and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The International Taxation System written by Andrew Lymer and published by Springer Science & Business Media. This book was released on 2012-12-06 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
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:
Download or read book International Taxation written by Adnan Islam and published by John Wiley & Sons. This book was released on 2020-09-01 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction. Information is provided for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017, this guide covers international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the United States. Key topics include: Export income Receipts in foreign currency Allocation and apportionment of deductions U.S. foreign tax credit fundamentals and special rules Initiation of foreign operations Foreign branches and affiliated companies Sale of use of tangible property Foreign business operations in the United States Foreign business sales of tangible property in the United States Foreign business provision of services in the United States Exploitation of business assets outside of the United States Use of foreign tangible/intangible property in the United States U.S. withholding taxes on foreign businesses FDII GILTI
Download or read book International Taxation written by Marnin J. Michaels and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Download or read book U S International Taxation written by Reuven Shlomo Avi-Yonah and published by . This book was released on 2005 with total page 616 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides law teachers with a relatively simple, easy to use casebook to teach U.S. international taxation. The field is notoriously complex-more so, perhaps, than any other area of Federal tax law. The focus is on how the details of the tax law fit into a broader structure, which is described in the introduction. Enables students to fit the particular issues they are working on into a larger context, to develop an intuition for where the problem areas may lie.
Download or read book International Taxation in a Nutshell written by Richard L. Doernberg and published by West Publishing Company. This book was released on 2001 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: After an introduction to the fundamentals of U.S. international taxation, the U.S. activities of foreign taxpayers and the foreign activities of U.S. citizens and residents are addressed. Special U.S. international tax provisions creating incentives and disincentives for certain conducts or forms of business transactions are looked at and the effect of U.S. transfer taxes (estate, gift and generation-skipping tax) on both resident and nonresident aliens is dealt with.
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 Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
Download or read book International Tax Primer written by Brian J. Arnold and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 421 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition. Unquestionably, the most important development in international tax since the publication of the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition explores in detail both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. Also new to the fifth edition are sections dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: taxation of residents on foreign income and nonresidents on domestic income; mechanisms used to mitigate the risks to taxpayers of international double taxation; transfer pricing rules to prevent the avoidance of tax by multinational corporations; anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Download or read book Time and Tax Issues in International EU and Constitutional Law written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.
Download or read book Principles of International Taxation written by Angharad Miller and published by A&C Black. This book was released on 2012-01-01 with total page 687 pages. Available in PDF, EPUB and Kindle. Book excerpt: This superb book will guide the reader through the key issues and practical aspects of international tax practice. It demonstrates how different global tax systems interact and how to prevent paying more tax than necessary. The basic principles of each aspect of international taxation are outlined and then examined in greater depth and detail. This updated third edition includes coverage of both UK and EU legislation and regulation, as well as the key cases and rulings. Complicated double taxation concepts are clearly illustrated with examples and diagrams to help the reader quickly understand how they'll apply in practice. Examples of policies adopted in other countries are included, along with specialist commentary and guidance.
Download or read book A Practical Guide to U S Taxation of International Transactions written by Robert Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
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 Fixing U S International Taxation written by Daniel N. Shaviro and published by Oxford University Press. This book was released on 2014-02-05 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
