Download or read book Territorial Taxes written by Charlotte Ecton and published by Nova Science Publishers. This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax reform is a perennial issue before Congress. One area of increasing attention is the taxation of U.S. companies on the income they earn abroad. Business leaders have been urging a movement toward a territorial tax, which would generally eliminate U.S. income taxes on active foreign source income. Tax on the income of foreign subsidiaries is deferred until repatriated and tax can be avoided by not repatriating income. Economists have traditionally analysed the foreign tax system in terms of economic efficiency. Economic theory tends to support, on efficiency grounds, a world-wide system in which income from U.S. investment earned abroad is subject to the same tax, or as close to the same tax as possible, as that on domestic investment. This book provides an overview of how the international tax system works and describes the magnitude and distribution of foreign source income and taxes, with a focus on the alternative features of a territorial tax and their consequences.
Download or read book Moving to a Territorial Income Tax written by Jane Gravelle and published by Createspace Independent Publishing Platform. This book was released on 2012-08-02 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Among potential tax reforms under discussion by Congress is revising the tax treatment of foreign source income of U.S. multinational corporations. Some business leaders have been urging a movement toward a territorial tax, which would eliminate some U.S. income taxes on active foreign source income. Under a territorial tax, only the country where the income is earned imposes a tax. Territorial proposals include the Grubert-Mutti proposal (included in President Bush's Advisory Panel on Tax Reform proposal in 2005) and, more recently, a draft Ways and Means Committee proposal and a Senate bill, S. 2091. The Fiscal Commission also proposed a territorial tax. Proposals have, however, also been made to increase the taxation of foreign source income, including S. 727, and proposals by President Obama. Although the United States has a worldwide system that includes foreign earnings in U.S. taxable income, two provisions cause the current system to resemble a territorial tax in that very little tax is collected. Deferral delays paying taxes until income is repatriated (paid as a dividend by the foreign subsidiary to its U.S. parent). When income is repatriated, credits for foreign taxes paid offset the U.S. tax due. Under cross-crediting, unused foreign tax credits from high tax countries or on highly taxed income can be used to offset U.S. tax on income in low tax countries. Some proponents of a territorial tax urge such a system on the grounds that the current system discourages repatriations. Economic evidence suggests that effect is small, in part because in normal circumstances a large share of income is retained for permanent reinvestment. Amounts held abroad may have increased, however, as firms lobbied for another repatriation holiday (similar to that adopted in 2004) that allowed firms to exempt most dividends from income on a one-time basis. Opponents are concerned about encouraging investment abroad. A territorial tax is generally not viewed as efficient because it favors foreign investment, but that increased outflow of investment is likely to have a small effect relative to the U.S. economy. Artificial shifting of profits into tax havens or low tax countries is a current problem that could be worsened under some territorial tax designs, and proposals have included measures to address this problem. Proposals also address the transitional issue of the treatment of the existing stock of unrepatriated earnings. The Ways and Means proposal would tax this stock of earnings, but at a lower rate, and use the revenues to offset losses from other parts of the plan, which would lead to a long-run revenue loss. S. 2091 has a similar approach. The Grubert-Mutti proposal does not have a specific transitional tax, but would raise revenue largely due to its disallowance of parent overhead expenses aimed at reducing profit shifting. The other two proposals also contain provisions to address profit shifting. In addition there are complicated issues in the design of a territorial tax, such as how to treat branches and dividends of firms in which the corporation is only partially owned. A number of issues arise from the ending of foreign tax credits, with perhaps the most significant one being the increased tax on royalties, which are currently subject to tax, have low or no foreign taxes, and would lose the shield of excess credits. The final section of the report briefly discusses some alternative options, including those in S.727 and in the Administration proposals. It also discusses hybrid approaches that combine territorial and worldwide systems in a more efficient way, including eliminating the disincentive to repatriate. One such approach is a minimum tax on foreign source income, which is proposed by the President in the context of current rules, but could be combined with a territorial system.
Download or read book Territorial vs Worldwide Corporate Taxation written by Ms.Thornton Matheson and published by International Monetary Fund. This book was released on 2013-10-03 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global investment patterns mean that effective taxation of foreign investors is of increasing importance to the economies of lower income countries. It is thus of considerable concern that the historical framework for cross-border income tax arrangements is not always well suited to allow low-income countries (LICs) effectively to generate tax revenues from profits on foreign direct investment (FDI). Several aspects of this framework contribute to the problem. This paper discusses, in particular, the likely effect of a shift by major economies from the system of worldwide corporate taxation toward a territorial system on the volume, distribution, and financing of FDI, focusing on LICs. It then empirically analyzes bilateral outbound FDI data for the UK for 2002–10 to determine whether the move to territoriality made corporations more sensitive to hostcountry statutory tax rates. Supporting evidence for this hypothesis is found for FDI financed from new equity.
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1990 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements Action 2 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2017-07-27 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
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 Territorial Income Tax Systems written by United States. Department of the Treasury and published by . This book was released on 1979 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Where Does Multinational Investment Go with Territorial Taxation Evidence from the UK written by Ms.Li Liu and published by International Monetary Fund. This book was released on 2018-01-13 with total page 49 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries. This paper assesses the causal effect of territorial taxation on real investments, using a unique dataset for multinational affiliates in 27 European countries and employing the difference-in-difference approach. It finds that the territorial reform has increased the investment rate of UK multinationals by 15.7 percentage points in low-tax countries. In the absence of any significant investment reduction elsewhere, the findings represent a likely increase in total outbound investment by UK multinationals.
Download or read book Tax Withholding and Estimated Tax written by and published by . This book was released on 1992 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Facts Concerning State and Territorial Taxes written by Arizona. State Tax Commission and published by . This book was released on 1914 with total page 1 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Income Tax on Territorial Employees of Alaska and Hawaii written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1926 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Territorial Income Tax Systems written by United States. Department of the Treasury and published by . This book was released on 1979 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Reform of U S International Taxation written by Jane G. Gravelle and published by DIANE Publishing. This book was released on 2011-04 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? Contents of this report: The Current System and Possible Revisions; Neutrality, Efficiency, and Competitiveness; Assessing the Existing Tax System; Territorial Taxation: The Dividend Exemption Proposal; A Residence-Based System in Practice; President Obama's Proposals to Restrict Deferral and Cross-Crediting; Tax Havens: Issues and Policy Options; General Reforms of the Corporate Tax and Implications for International Tax Treatment. Charts and tables. This is a print on demand edition of an important, hard-to-find publication.
Download or read book The Flat Tax written by Robert E. Hall and published by Hoover Press. This book was released on 2013-09-01 with total page 245 pages. Available in PDF, EPUB and Kindle. Book excerpt: This new and updated edition of The Flat Tax—called "the bible of the flat tax movement" by Forbes—explains what's wrong with our present tax system and offers a practical alternative. Hall and Rabushka set forth what many believe is the most fair, efficient, simple, and workable tax reform plan on the table: tax all income, once only, at a uniform rate of 19 percent.
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Download or read book Taxation and State Building in Developing Countries written by Deborah Brautigam and published by Cambridge University Press. This book was released on 2008-01-10 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is a widespread concern that, in some parts of the world, governments are unable to exercise effective authority. When governments fail, more sinister forces thrive: warlords, arms smugglers, narcotics enterprises, kidnap gangs, terrorist networks, armed militias. Why do governments fail? This book explores an old idea that has returned to prominence: that authority, effectiveness, accountability and responsiveness is closely related to the ways in which governments are financed. It matters that governments tax their citizens rather than live from oil revenues and foreign aid, and it matters how they tax them. Taxation stimulates demands for representation, and an effective revenue authority is the central pillar of state capacity. Using case studies from Africa, Asia, Eastern Europe and Latin America, this book presents and evaluates these arguments, updates theories derived from European history in the light of conditions in contemporary poorer countries, and draws conclusions for policy-makers.
Download or read book Tax Administration 2021 Comparative Information on OECD and other Advanced and Emerging Economies written by OECD and published by OECD Publishing. This book was released on 2021-09-15 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
