Download or read book Norms and Transfer Taxes written by Joseph M. Dodge and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter lays out four normative categories and then applies them to the design of the federal transfer taxes. The norm categories, familiar to tax theorists, are derived by cross-cutting the internal/external (to tax) and means/ends dichotomies to yield: (1) social justice (external/ends), (2) economic efficiency (external/means), (3) allocative fairness (internal/ends) and (4) administrative feasibility (internal/means). Although the content of social justice norms is contestable, in legal (tax) academic discourse the discussion inevitably focuses on (re)distribution of material resources. The norm for allocative tax fairness is that of ability to pay. Accordingly, the principal positive rationales of a wealth transfer tax system are to curb excessive concentrations of wealth acquired by gratuitous transfer and/or to supplement the income tax to construct a tax base that fully conforms to the ability-to-pay principle. In either case, the tax would be imposed on transferees, not transferors, by way of (a) an accessions tax with large exemptions (to curb excessive acquisitions of unearned wealth) and/or (b) inclusion of gratuitous receipts in the income tax base (to achieve a comprehensive ability-to-pay tax base). Both approaches are administratively feasible. The economic efficiency objections to these approaches (relative to other forms of tax that would raise the same revenue) are found to be unpersuasive.
Download or read book United States Inheritance and Transfer Taxes written by Joseph Fitz Randolph and published by . This book was released on 1917 with total page 264 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Master Estate and Gift Tax Guide written by CCH Tax Law Editors and published by CCH. This book was released on 2007-12 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: CCH's U.S. Master Estate and Gift Tax Guide is a concise and reliable handbook for both tax advisors and estate representatives involved in federal estate and gift tax planning, return preparation and tax payment. This trusted reference provides clear explanations of the laws relating to federal estate, gift and generation-skipping transfer taxes to give readers the solid understanding they need to understand and apply today's complex wealth transfer tax rules.
Download or read book Estate Planning Chapter 14 written by Cheryl E. Hader and published by Practising Law Institute. This book was released on 2000 with total page 473 pages. Available in PDF, EPUB and Kindle. Book excerpt: Estate Planning & Chapter 14 highlights the transfers that are exempt from the application of 2701 covering the transfer tax treatment of accumulated qualified payments; transfers that are exempt from the application of 2702 covering transfers of interest in trusts; adjustments that can be made under 2701 to avoid double taxation; and types of transfers under 2702 that minimize the risk of double taxation.
Download or read book Federal Transfer Taxes Code and Regulations written by Kevin Yamamoto and published by Foundation Press. This book was released on 2006-08-04 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Federal Transfer Taxes?Code and Regulations contains the full Code provisions and Regulations of the Federal Estate Tax, the Federal Gift Tax, the Federal Generation-Skipping Transfer Tax, the Special Valuation Rules of new Chapter 14, and pertinent Income Tax and Regulatory Provisions (including all of Subchapter J). Temporary and proposed regulations are included. The book also contains selected Administration and Procedure provisions and regulations. This publication is designed to relieve the frustration of Code books that are hard to read or jumbled up with extraneous information separating the Code from the Regulations. The Code and Regulations in this long-standing publication are set forth in easy-to-read type, and each Code provision is followed by the Regulations interpreting that provision, presented in double columns.
Download or read book Easy Review written by Law Rules Editorial Staff and published by . This book was released on 1998-07 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Federal Tax Rules Relating to Disclaimer of Property Interests Created by Transfers written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1984 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 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 (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: 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 US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
Download or read book Federal Taxation of Wealth Transfers written by Stephanie J. Willbanks and published by . This book was released on 2004 with total page 584 pages. Available in PDF, EPUB and Kindle. Book excerpt: If you want to take a problem approach to estate and gift taxation, be sure to consider this new casebook. Federal Taxation of Wealth Transfers emphasizes planning and integrates problems with statutes, regulation cases and administrative regulations to create a teachable, accessible casebook. Instructors will appreciate the casebookiquest;s logical, flexible organization: Begins with general introductory chapters covering history and policy, income tax issues, and valuation and calculation of the tax. Discrete sections address gift tax, estate tax, deductions and credits, and generation-skipping tax. Each part of the book is self contained for easy reorganization to fit various teaching approaches. the author encourages student comprehension: Ample textual material puts the cases and problems in context. Problems have been extensively class-tested for effectiveness. Emphasis on problem-solving, statutory construction, and policy analysis skills. the casebook is the ideal length for a three-credit basic wealth transfer tax class. Problems foster discussion not only of rules, but also of policy and planning issues. an in-depth Teacher's Manual includes analysis of the cases and problems. For a modern exposition of the full range of tax implications involved in the transfer of wealth, turn to Federal Taxation of Wealth Transfers: Cases and Problems .
Download or read book Practical Guide to U S Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Download or read book Transfer Tax Payment and Apportionment written by Jeffrey N. Pennell and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... is a study of the law concerning the payment and apportionment of federal and state wealth transfer taxes. The portfolio discusses both federal and state law and examines the interplay of those rules with the tax payment provisions contained in wills and other estate planning instruments. The portfolio is designed principally for estate planners, for trust and estate fiduciaries and their counsel, and for lawyers and other professionals involved in both tax and nontax litigation concerning apportionment matters.
Download or read book Understanding Estate Gift and Generation skipping Transfer Taxes written by and published by . This book was released on 2002 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book United States Inheritance and Transfer Taxes written by Joseph Fitz Randolph and published by Palala Press. This book was released on 2016-04-28 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work has been selected by scholars as being culturally important, and is part of the knowledge base of civilization as we know it. This work was reproduced from the original artifact, and remains as true to the original work as possible. Therefore, you will see the original copyright references, library stamps (as most of these works have been housed in our most important libraries around the world), and other notations in the work.This work is in the public domain in the United States of America, and possibly other nations. Within the United States, you may freely copy and distribute this work, as no entity (individual or corporate) has a copyright on the body of the work.As a reproduction of a historical artifact, this work may contain missing or blurred pages, poor pictures, errant marks, etc. Scholars believe, and we concur, that this work is important enough to be preserved, reproduced, and made generally available to the public. We appreciate your support of the preservation process, and thank you for being an important part of keeping this knowledge alive and relevant.
Download or read book Illinois real Estate Transfer Tax Act rules written by Illinois. Department of Revenue and published by . This book was released on 1971 with total page 3 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
Download or read book Income Taxes Stock Transfer Rules Carryover of Tax Attributes Us Internal Revenue Service Regulation Irs 2018 Edition written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-09 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt: Income taxes - Stock transfer rules - carryover of tax attributes (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Income taxes - Stock transfer rules - carryover of tax attributes (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is described in both section 367(b) and section 381 of the Internal Revenue Code (Code). This book contains: - The complete text of the Income taxes - Stock transfer rules - carryover of tax attributes (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Download or read book Tax Planning for Family Wealth Transfers written by Howard M. Zaritsky and published by Warren Gorham & Lamont. This book was released on 1997 with total page 2166 pages. Available in PDF, EPUB and Kindle. Book excerpt:
