Download or read book The dilemma of international tax arbitrage written by Shay Nisan Menuchin and published by . This book was released on 2005 with total page 518 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Arbitrage written by Nigel Feetham and published by Spiramus Press Ltd. This book was released on 2011 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice.
Download or read book Tax Arbitrage and the Changing Structure of International Tax Law written by Luca Dell'Anese and published by . This book was released on 2006 with total page 270 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Download or read book A Critique of the Political Economy of International Tax Arbitrage written by Kieran Tahir and published by . This book was released on 2020 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: This thesis conducts a critique of the political economy of international tax arbitrage. It seeks to address a limitation within the tax avoidance literature, which generally fails to critically examine the role of states and the state system in facilitating this widespread practice. Recognising that the practice of tax avoidance is ideologically and functionally grounded in the concept of arbitrage, this thesis calls for the reconceptualisation of tax avoidance as tax arbitrage. In doing so it draws upon a body of literature dedicated to political economic analysis, emphasising the entrenchment of the financial logic of arbitrage within state institutions. It adopts Aotearoa New Zealand as a case study to elucidate state-level justifications for the tax competitive behaviour that facilitates the global regime of tax arbitrage. This thesis seeks to establish that tax arbitrage is not merely peripheral behaviour as commonly suggested within mainstream academic discourse. It does so by providing an account of the global apparatus, institutions and logical foundations of the offshore financial network within which international tax arbitrage takes place. It demonstrates the extensive planning and coordination that is characteristic of this global network. Furthermore, this thesis argues that the actions of the wealth managers and offshore clientele that utilise this network have engendered a radical transformation of the state form that is today fundamental to the operation of the global economy. Governments around the world are significantly impacted by the loss in revenue that this has brought about, inhibiting their ability to provide essential services, undermining democratic legitimacy and threatening the rule of law. Against a backdrop of soaring global inequality, this thesis seeks to understand the key political and economic dynamics that prevent tax arbitrage from being effectively challenged. In light of such consequences, this thesis argues for the development of policy mechanisms capable of effectively regulating tax arbitrage. Ultimately, this thesis presents a progressive internationalist vision for the taxation of capital in order to curtail the dominance that the tax arbitrage regime has over the global political landscape.
Download or read book International Tax as International Law written by Reuven S. Avi-Yonah and published by Cambridge University Press. This book was released on 2007-09-10 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Download or read book Taxation in the Global Economy written by Assaf Razin and published by University of Chicago Press. This book was released on 2008-04-15 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increasing globalization of economic activity is bringing an awareness of the international consequences of tax policy. The move toward the common European market in 1992 raises the important question of how inefficiencies in the various tax systems—such as self-defeating tax competition among member nations—will be addressed. As barriers to trade and investment tumble, cross-national differences in tax structures may loom larger and create incentives for relocations of capital and labor; and efficient and equitable income tax systems are becoming more difficult to administer and enforce, particularly because of the growing importance of multinational enterprises. What will be the role of tax policy in this more integrated world economy? Assaf Razin and Joel Slemrod gathered experts from two traditionally distinct specialties, taxation and international economics, to lay the groundwork for understanding these issues, which will require the attention of scholars and policymakers for years to come. Contributors describe the basic provisions of the U.S. tax code with respect to international transactions, highlighting the changes contained in the U.S. Tax Reform Act of 1986; explore the ways that tax systems influence the decisions of multinationals; examine the effect of taxation on trade patterns and capital flows; and discuss the implications of the opening world economy for the design of optimal international tax policy. The papers will prove valuable not only to scholars and students, but to government economists and international tax lawyers as well.
Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 709 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Download or read book Debt Bias and Other Distortions written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2009-12-06 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax distortions are likely to have encouraged excessive leveraging and other financial market problems evident in the crisis. These effects have been little explored, but are potentially macro-relevant. Taxation can result, for example, in a net subsidy to borrowing of hundreds of basis points, raising debt-equity ratios and vulnerabilities from capital inflows. This paper reviews key channels by which tax distortions can significantly affect financial markets, drawing implications for tax design once the crisis has passed.
Download or read book International Aspects of the US Taxation System written by Felix I. Lessambo and published by Palgrave Macmillan. This book was released on 2016-09-29 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.
Download or read book Japan s Corporate Income Tax written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2014-08-04 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper explores how corporate income tax reform can help Japan increase investment and boost potential growth. Using international and Japan-specific empirical estimates of corporate tax elasticities, investment is predicted to expand by around 0.4 percent for each point of rate reduction. International consensus estimates suggest further that between 10 and 30 percent of the static revenue loss could be recovered in the long run through dynamic scoring, although Japan’s offset may be closer to the lower bound. Compensating fiscal measures are necessary in light of Japan’s tight fiscal constraints. The scope for base broadening in the corporate income tax is found to be limited and some forms of base broadening will undo positive investment effects of a rate cut. Alternative revenue sources include higher consumption and property taxes. A gradual approach toward lowering tax rates mitigates windfall gains and reduces short-run revenue costs. An incremental allowance-for-corporate-equity system could boost investment with limited fiscal costs in the short run.
Download or read book Corporate Social Responsibility and the Institutional Investor written by Bevis Longstreth and published by . This book was released on 1973 with total page 146 pages. Available in PDF, EPUB and Kindle. Book excerpt: Report on the growing awareness, in the USA, of the social implications of investment policies and the social responsibility of business - covers shareholder campaigns, the concept of corporate social responsibility, efforts at social auditing, the current thinking of institutional investors (such as universitys), etc., and comments on four previous studies. Bibliography pp. 100 to 104 and references.
Download or read book Taxes and Business Strategy written by Myron S. Scholes and published by . This book was released on 2015-01-03 with total page 528 pages. Available in PDF, EPUB and Kindle. Book excerpt: For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience-for you and your students: *Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide students with relevant examples from both classroom and real-world consulting experience. *Teach students the practical uses for business strategy: Students learn important concepts that can be applied to their own lives. *Reinforce learning by using in-depth analysis: Analysis and explanatory material help students understand, think about, and retain information.
Download or read book Issues in International Taxation and the Role of the IMF written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2013-06-28 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the discussion of the Board work program on June 3, 2013, it was urged that the Fund be more present in current discussions of international tax issues. This note reviews key issues and initiatives in this area, and sets out a work plan that is focused on the Fund‘s mandate and macroeconomic expertise and that complements the work of other institutions, notably the OECD.
Download or read book Tax Us If You Can written by Tax Justice Network-Africa and published by Fahamu/Pambazuka. This book was released on 2011-10-20 with total page 95 pages. Available in PDF, EPUB and Kindle. Book excerpt: This short introduction to issues of tax justice explains the meaning and causes of tax injustice and offers options for a better future. Providing insight into the specific failures of Africa s tax systemand the associated problems of capital flight, tax evasion, tax avoidance, and tax competitionthis book explores the role of governments, parliaments, and taxpayers, and asks how stakeholders can help achieve tax justice. Arguing that tax revenues are essential for establishing independent states of free citizens, it demonstrates how the tax consensus promoted by multilateral agencies, such as the World Bank and the International Monetary Fund, has influenced tax policy in Africa and led to a reduction in government revenues in many countries. "
Download or read book Transnational Legal Orders written by Terence C. Halliday and published by Cambridge University Press. This book was released on 2015-01-19 with total page 559 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transnational Legal Orders offers an empirically grounded approach to the emergence of legal orders beyond nation-states that reframes the study of law and society.
