Download or read book The Elusive Definition of Corporate Tax Residence written by David Elkins and published by . This book was released on 2018 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the literature has extensively discussed the issue of corporation residence, it has paid little attention to the terms of reference of the debate. A typical argument will take the following form: the law should adopt Definition D as appropriate because it closely conforms to Principle P. However, such an argument is unpersuasive unless it also provides a convincing explanation for why P is the appropriate principle. Without such an explanation, the fact that D closely conforms to P is a brute fact with no normative value. Nonetheless, the literature generally ignores this first, crucial step. In most cases, it examines tests of corporate residence without a cogent justification for the principles by which it evaluates those tests.This Article will attempt to move the discourse to a more theoretical level by focusing attention not on the definitions themselves but rather on the criteria upon which commentators rely, either explicitly or implicitly, when considering the merits of particular definitions of corporate residence.A survey of the literature reveals four criteria for evaluating tests of corporate residence. Part I considers the three most commonly relied upon criteria: manipulability, clarity, and benefit. It argues that all three are bereft of relevant normative content. Consequently, the fact that a particular test conforms to one or more of these criteria does not constitute adequate grounds for its adoption.The fourth criterion, and the newest member of the pantheon, is purposiveness. As opposed to the more traditional criteria, purposiveness does have normative value: a demonstration that a proposed test conforms to this criterion would constitute a reasonable argument in support of that test. Part II describes this criterion and explores whether it is possible to formulate a test that conforms to it. The answer is that it does not appear possible to do so.The fact that no test appears capable of satisfying the demands of the only criterion with normative value suggests that the quest for an appropriate definition of corporate residence may be a futile endeavor. The Conclusion summarizes the findings and offer some speculation as to why an acceptable definition of corporate residence is so elusive.
Download or read book Advanced Introduction to International Tax Law written by Reuven S. Avi-Yonah and published by Edward Elgar Publishing. This book was released on 2019 with total page 231 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
Download or read book The Law of Federal Income Taxation written by and published by . This book was released on 1942 with total page 1228 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Policy and the Economy written by and published by . This book was released on 1994 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Unrelated Business Income Tax written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1988 with total page 650 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Sochurek V Commissioner of Internal Revenue written by and published by . This book was released on 1961 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Reports of the United States Tax Court written by United States. Tax Court and published by . This book was released on 1978 with total page 1174 pages. Available in PDF, EPUB and Kindle. Book excerpt: Kept up to date by a monthly publication called: United States. Tax Court. Reports.
Download or read book Reports of the Tax Court of the United States written by United States. Tax Court and published by . This book was released on 1962 with total page 1274 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Fixing U S International Taxation written by Daniel N. Shaviro and published by Oxford University Press, USA. This book was released on 2014-04 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Download or read book International Business Taxation written by Sol Picciotto and published by Praeger. This book was released on 1992-03-02 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.
Download or read book The Known Citizen written by Sarah E. Igo and published by Harvard University Press. This book was released on 2020-03-10 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Washington Post Book of the Year Winner of the Merle Curti Award Winner of the Jacques Barzun Prize Winner of the Ralph Waldo Emerson Award “A masterful study of privacy.” —Sue Halpern, New York Review of Books “Masterful (and timely)...[A] marathon trek from Victorian propriety to social media exhibitionism...Utterly original.” —Washington Post Every day, we make decisions about what to share and when, how much to expose and to whom. Securing the boundary between one’s private affairs and public identity has become an urgent task of modern life. How did privacy come to loom so large in public consciousness? Sarah Igo tracks the quest for privacy from the invention of the telegraph onward, revealing enduring debates over how Americans would—and should—be known. The Known Citizen is a penetrating historical investigation with powerful lessons for our own times, when corporations, government agencies, and data miners are tracking our every move. “A mighty effort to tell the story of modern America as a story of anxieties about privacy...Shows us that although we may feel that the threat to privacy today is unprecedented, every generation has felt that way since the introduction of the postcard.” —Louis Menand, New Yorker “Engaging and wide-ranging...Igo’s analysis of state surveillance from the New Deal through Watergate is remarkably thorough and insightful.” —The Nation
Download or read book Advanced Issues in International and European Tax Law written by Christiana HJI Panayi and published by Bloomsbury Publishing. This book was released on 2015-12-03 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world.
Download or read book The Puppet Masters written by Emile van der Does de Willebois and published by World Bank Publications. This book was released on 2011-11-01 with total page 230 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report examines the use of these entities in nearly all cases of corruption. It builds upon case law, interviews with investigators, corporate registries and financial institutions and a 'mystery shopping' exercise to provide evidence of this criminal practice.
Download or read book Tax Reform 1969 written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1969 with total page 540 pages. Available in PDF, EPUB and Kindle. Book excerpt: Considers H.R. 5250 and H.R. 202 and related bills, general proposals and policy recommendations, to close tax advantages for unearned income and provide larger tax deduction for families with handicapped or retarded children.
Download or read book The Draft Finance Bill 2013 written by Great Britain: Parliament: House of Lords: Select Committee on Economic Affairs and published by The Stationery Office. This book was released on 2013-03-13 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Draft Finance Bill 2013 (HL 139) evaluates the draft Finance Bill which, following detailed consultations based on the findings of an independent study group, includes proposals for a General Anti-Abuse Rule (GAAR), narrowly targeted at abusive transactions which fail a stringent 'double reasonableness' test. The provisions also include the formation of an Advisory Panel to agree guidance and give its opinion on the application of the double reasonableness test to a given set of tax arrangements. Most agree the narrow focus was appropriate. Some witnesses argued that HM Revenue and Customs (HMRC) should set up a clearance system to reduce uncertainty about where the GAAR would apply. Many witnesses were very concerned at the application of the GAAR to transactions involving inheritance tax planning. The Bill also includes an Annual Residential Property Tax Package (ARPT) which is part of a package of measures to address Stamp Duty Land Tax avoidance by
Download or read book Tax Policy Leverage and Macroeconomic Stability written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2016-12-10 with total page 78 pages. Available in PDF, EPUB and Kindle. Book excerpt: Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
