Download or read book Substance Over Form in Transfer Tax Adjudication written by Jay A. Soled and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The elevated exemption level under the federal transfer tax system (now in excess of $23 million for a married couple) has opened up new and abusive tax-avoidance opportunities. In many areas of the tax law, the substance over form doctrine historically has been effective in controlling such abuses; however, for a myriad of reasons, transfer tax jurisprudence has been marred by the reluctance of courts to embrace this doctrine. In this analysis, we urge reconsideration of that posture.

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 Global Perspectives on Income Taxation Law written by Reuven Shlomo Avi-Yonah and published by Oxford University Press, USA. This book was released on 2011 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Global Perspectives on Income Taxation Law, Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class. It is arranged by subject matter in the order in which they are usually covered in U.S. tax law classes. The materials are drawn from a wide variety of countries, including developing countries.

Download or read book Akron Tax Journal written by and published by . This book was released on 2006 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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Download or read book The Transfer Pricing Law Review written by Steve Edge and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Federal Tax Course 2004 written by Toolkit Media Group and published by . This book was released on 2003-03 with total page 1894 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Caterpillar s Offshore Tax Strategy written by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations and published by . This book was released on 2014 with total page 1284 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Report of Investigation of Enron Corporation and Related Entities Regarding Federal Tax and Compensation Issues and Policy Recommendations written by and published by Joint Committee. This book was released on 2003 with total page 756 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Federal Tax Course School Edition written by CCH Incorporated Staff and published by . This book was released on 1998-06 with total page 1822 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Statement of Procedural Rules written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Income Tax Treatment of Cooperatives Handling of losses written by Donald A. Frederick and published by . This book was released on 1993 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Hong Kong Taxation written by Ayesha Macpherson Lau and published by The Chinese University of Hong Kong Press. This book was released on 2019-01-15 with total page 1002 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book covers the major areas of Hong Kong taxation--Profits Tax, Salaries Tax, Property Tax, Personal Assessment and Stamp Duty as well as a general overview of international tax issues and how they pertain to Hong Kong. It explains the principles and practice of Hong Kong taxation law together with the relevant Court and Board of Review decisions and contains numerous practical examples. The new edition includes legislative changes up to 31 July 2018 as well as the latest developments pertaining to the OECD's Base Erosion and Profit Shifting (BEPS) project and the proposed measures to be adopted by Hong Kong; the principles and practice of Hong Kong taxation law together with the relevant Court and Board of Review decisions and contains numerous practical examples. The new edition includes legislative changes up to 31 July 2018 as well as the latest developments pertaining to the OECD's Base Erosion and Profit Shifting (BEPS) project and the proposed measures to be adopted by Hong Kong.

Download or read book Handbook for Chapter 7 Trustees written by and published by . This book was released on 2001 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation Actions 8 10 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

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