Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation and published by . This book was released on 1953 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Download or read book The Economic Effects of Dividend Taxation written by Kenneth James McKenzie and published by . This book was released on 1996 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Handbook on Corporate Distributions and Dividends written by D. Larry Crumbley and published by Prentice Hall. This book was released on 1981 with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Dividends Under the Income Tax written by Daniel Mark Holland and published by . This book was released on 1962 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Cross Border Dividends Paid to Individuals from an EU Perspective written by Erwin Nijkeuter and published by Kluwer Law International B.V.. This book was released on 2012-08-01 with total page 229 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 379 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Download or read book Paying dividends written by United States. Congress. House. Committee on Financial Services. Subcommittee on Oversight and Investigations and published by . This book was released on 2003 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Taxation of Corporations and Shareholders written by Martin Norr and published by Springer Science & Business Media. This book was released on 2013-06-29 with total page 222 pages. Available in PDF, EPUB and Kindle. Book excerpt: This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.
Download or read book Elimination of the Double Tax on Dividends written by American Institute of Certified Public Accountants and published by . This book was released on 1976 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Estimates of Income Unreported on Individual Income Tax Returns written by United States. Internal Revenue Service and published by . This book was released on 1979 with total page 180 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Individual retirement arrangements IRAs written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States written by International Monetary Fund and published by International Monetary Fund. This book was released on 1990-07-01 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.
Download or read book Tax Withholding and Estimated Tax written by and published by . This book was released on 1993 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Dividends and Corporate Distributions written by Daniel M. Schneider and published by Warren Gorham & Lamont. This book was released on 1995-01-01 with total page 1000 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treatment of Interest and Dividends Charitable Contributions of Certain Inventory and Uranium Litigation Settlement Discounts written by United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management and published by . This book was released on 1982 with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Encyclopedia of Taxation Tax Policy written by Joseph J. Cordes and published by The Urban Insitute. This book was released on 2005 with total page 522 pages. Available in PDF, EPUB and Kindle. Book excerpt: "From adjusted gross income to zoning and property taxes, the second edition of The Encyclopedia of Taxation and Tax Policy offers the best and most complete guide to taxes and tax-related issues. More than 150 tax practitioners and administrators, policymakers, and academics have contributed. The result is a unique and authoritative reference that examines virtually all tax instruments used by governments (individual income, corporate income, sales and value-added, property, estate and gift, franchise, poll, and many variants of these taxes), as well as characteristics of a good tax system, budgetary issues, and many current federal, state, local, and international tax policy issues. The new edition has been completely revised, with 40 new topics and 200 articles reflecting six years of legislative changes. Each essay provides the generalist with a quick and reliable introduction to many topics but also gives tax specialists the benefit of other experts' best thinking, in a manner that makes the complex understandable. Reference lists point the reader to additional sources of information for each topic. The first edition of The Encyclopedia of Taxation and Tax Policy was selected as an Outstanding Academic Book of the Year (1999) by Choice magazine."--Publisher's website.
