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 U S Income Tax Treaties written by Richard L. Doernberg and published by . This book was released on 1999 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Download or read book Interpretation and Application of Tax Treaties written by Ned Shelton and published by Bloomsbury Professional. This book was released on 2004-01-01 with total page 662 pages. Available in PDF, EPUB and Kindle. Book excerpt: "This book provides an excellent, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Other highlights include case studies and OECD model treaties. Written by an expert in the field and taking the practical approach rather than the academic, this truly is an essential global tool for the tax adviser wishing to use tax treaties in tax planning."
Download or read book Canada U S Tax Treaty written by Fraser Milner Casgrain (Firm) and published by CCH Canadian Limited. This book was released on 2009 with total page 612 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 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 The Meaning of enterprise business and business Profits Under Tax Treaties and EU Tax Law written by Guglielmo Maisto and published by IBFD. This book was released on 2011 with total page 675 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Meaning of "Enterprise", "Business" and "Business Profits" under Tax Treaties and EU Tax Law, comprising the proceedings and working documents of an annual seminar held in Milan in November 2010, provides an in-depth analysis of the meaning of these three essential concepts in relevant tax treaties and law. The analysis starts from an EU tax law perspective, with a particular emphasis on the European Directives. The above concepts are then considered from domestic tax law viewpoints. The book then moves to tax treaty law. Most notably, an examination of the history and interpretation of the concepts of "enterprise", "business" and "business profits" is presented, starting from the works of the League of Nations to the current OECD Model Tax Convention. Next, specific tax treaty issues are considered. In particular, the controversial issues concerning the interpretation of the notions of "enterprise" and "enterprise of a Contracting State" are discussed. Also, the concepts of "profits" and "business profits" are thoroughly reviewed. The concept of "enterprise" in the context of the non-discrimination clause laid down by Art. 24 of the OECD Model Tax Convention is then examined. Individual country surveys provide an in-depth analysis of the aforementioned concepts and issues from a national viewpoint in selected European and North American jurisdictions, as well as in Australia and Japan. The book concludes with a round-table discussion among some of the most renowned international tax scholars on the desirability to change the OECD Model Tax Convention and its Commentaries. This book is essential reading for all those dealing with issues of taxation of enterprises engaged in cross-border activities and can be considered a new cornerstone in the subject matter."--Publisher's website
Download or read book Corporate Loss Utilisation through Aggressive Tax Planning written by OECD and published by OECD Publishing. This book was released on 2011-08-03 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
Download or read book United States Estate and Gift Tax Treaties written by Jeffrey A. Schoenblum and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties to which the United States is a party, as well as the income tax treaty with Canada, which bears on U.S. transfer taxes as well as Canadian income tax at death. The portfolio is divided into six parts. Part I: Introduction, explains the purpose and types of transfer tax treaties. Part II: Situs-Type Treaties, describes when situs-type transfer tax treaties apply and explains how a situs-type treaty assigns primary taxing jurisdiction to one country. It also analyzes the effect that situs-type treaties have on the deductions and credits of treaty countries. Part III: Domicile-Type Treaties, describes when domicile-type treaties apply and how these treaties assign primary taxing jurisdiction. It also analyzes the situs rules that are incorporated into domicile-type treaties, the effect that domicile-type treaties have on the deductions, exemptions, and credits of treaty countries, and the general operation of the treaties' nondiscrimination provisions. Part IV: Special, Administrative, and Enforcement Provisions, discusses the ways in which transfer tax treaties enable a treaty country to enforce the collection of death taxes and exchange information with the other country, as well as issues that a taxpayer subject to a treaty may face in reporting income. Part V: Treaty Interpretation, sets forth the principles of treaty interpretation and construction. Part VI: Particular Treaty Analysis, discusses the details of each transfer tax treaty.
Download or read book United States Income Tax Treaties written by Klaus Vogel and published by Springer. This book was released on 1989 with total page 1088 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive loose-leaf guide analysing United States income tax treaties. The commentary is divided into three parts providing general background information regarding income tax treaties and the model treaty process, commentary of the individual provisions of the US Model and of existing US treaties, appendices are included.
Download or read book Tax Treaties and Domestic Law written by Guglielmo Maisto and published by IBFD. This book was released on 2006 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Download or read book The Interpretation of Income Tax Treaties with Particular Reference to the Commentaries on the OECD Model written by and published by . This book was released on 2005-01-01 with total page 350 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book United States Tax Treaties written by United States and published by Springer. This book was released on 1991-02-05 with total page 678 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Download or read book Fundamental Issues and Practical Problems in Tax Treaty Interpretation written by Michael Schilcher and published by . This book was released on 2008 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume deals in Part I with general principles of tax treaty interpretation, including many general issues of international law and especially treaty law. Part II is dedicated to specific tax treaty provisions that trigger particularly interesting interpretation questions. Part III is concerned with situations in which states disagree on the interpretation of tax treaties.
Download or read book Source Versus Residence written by Michael Lang and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Download or read book Model Tax Convention on Income and on Capital Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 656 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
