Download or read book Irish Capital Gains Tax 2023 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2023-04-28 with total page 1501 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Given the depth of detail, the comprehensive treatment of the subject, and the clear explanations of each area of this important tax for practising solicitors, this is undoubtedly the reference book for Irish capital gains tax.” The Law Society Gazette (review of the 2020 edition). Provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2022. This title is included in Bloomsbury Professional's Irish Tax online service.
Download or read book Irish Capital Gains Tax 2020 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2020-11-21 with total page 1644 pages. Available in PDF, EPUB and Kindle. Book excerpt: Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2019, which includes significant amendments in relation to the Tax Consolidation Act 1997 including exit tax, transfer pricing, and hybrid entities and instruments. Contents include: Statutory interpretation; What is an asset; What is a disposal; Persons chargeable; Married couples and civil partnerships; Taxation of partnerships; Computational rules; Shares; Financial instruments; Debts; Trusts; Anti-avoidance; Companies; Residence; Foreign tax matters; CA 2014 transactions.
Download or read book Irish Capital Gains Tax 2021 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2021-10-22 with total page 1622 pages. Available in PDF, EPUB and Kindle. Book excerpt: Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2020. Contents include: Statutory interpretation; What is an asset; What is a disposal; Persons chargeable; Married couples and civil partnerships; Taxation of partnerships; Computational rules; Shares; Financial instruments; Debts; Trusts; Anti-avoidance; Companies; Residence; Foreign tax matters; CA 2014 transactions.
Download or read book Irish Capital Gains Tax 2022 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2022-07-04 with total page 1479 pages. Available in PDF, EPUB and Kindle. Book excerpt: “Given the depth of detail, the comprehensive treatment of the subject, and the clear explanations of each area of this important tax for practising solicitors, this is undoubtedly the reference book for Irish capital gains tax.” The Law Society Gazette (review of the 2020 edition). Provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2021. This title is included in Bloomsbury Professional's Irish Tax online service.
Download or read book The Missing Keystone of Income Tax Treaties written by Joanna Wheeler and published by IBFD. This book was released on 2012 with total page 449 pages. Available in PDF, EPUB and Kindle. Book excerpt: Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respect of the income for which treaty benefits are claimed. This "missing keystone" causes two major problems of interpretation. One problem arises if the contracting states attribute the income to different persons; the myriad ways in which such a conflict can occur is illustrated by an extensive comparison of the domestic law of the Netherlands and the United Kingdom in this respect. This missing keystone also causes a disconnection between the two principal conditions for treaty entitlement. The treaty residence of the claimant is based on a general liability to tax in a contracting state, whereas the distributive articles focus on the ownership of the income. Interpretation problems arise if domestic law imposes a tax liability on a person who is not the owner of the income, for example under anti-avoidance legislation or a corporate group regime. In order to eliminate this fundamental flaw, the thesis proposes a "new approach" in which the criterion for treaty entitlement is liability to tax on the income, backed up by substantial connections between the income and the treaty claimant and between the treaty claimant and the residence state. The new approach is tested in various situations, many of them decided cases, and proves to give appropriate policy results while respecting the tax sovereignty of states. The thesis includes a proposal for a re-draft of the OECD Model on this basis."
Download or read book Corporate Residence written by David Hughes and published by A&C Black. This book was released on 2013-01-01 with total page 303 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is about the UK's approach to determining the residence status of corporations and thus their exposure to UK tax. If companies are not managed and controlled in the correct way, they could unintentionally become UK resident and so be rendered subject to UK taxes. The question of where a company is actually resident has become increasingly significant, with the international nature of so many business transactions today, including e-commerce transactions. Table of Contents include: The Importance of UK Residence Status * The Incorporation Rule * Central Management and Control (The Case Law Test) * FA 1994 S249 and the Impact of Tax Treaties on the Determination of Residence * Place of Effective Management * HMRC Practice * The Application of the Case Law Test to Subsidiaries * Peripatetic Boards * UK Coordination Centers * The Implications of Modern Forms of Communication * Directors Located in the UK and Overseas * Outside Interference: Shadow Directors, and other Outsiders * Conclusion
Download or read book Taxation of Trusts in South Africa written by Michael Honiball and published by Siber Ink. This book was released on 2009-12-18 with total page 469 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Taxation of Trusts in South Africa is the first book to exclusively cover the direct and indirect taxation of trusts in South Africa, including a look at the application of the exchange control regulations to both onshore and offshore trusts.
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Download or read book Tax Schedule written by Eile Gibson and published by Spiramus Press Ltd. This book was released on 2016-10-10 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explains the underlying rationale of the key provisions of the tax schedule, and provides updated model long-form and short-form warranties and tax indemnities. These are also included on a disk, so that practitioners can download and adapt the model documents for their own transactions. Since January 2014 we have witnessed continued erosion of the powers of the tax evasion industry including a new Targeted Anti-Avoidance Rule (TAAR), increased penalties and new HMRC powers, major changes the taxation of UK property for non-UK residents and non-UK domiciles, and a recently introduced investors’ relief, similar to entrepreneurs’ relief but which is available to non-employees and directors. The book has been updated to reflect these developments. The purpose of the book is to explain and simplify issues for tax advisors involved in transactions of buying and selling companies and business, enabling negotiations between tax advisors to keep sight of the commercial reality of the transaction (a sale by a willing seller to a willing buyer). The purpose of the tax schedule is to determine where responsibilities and risks will lie following the completion of the transaction, as well as to re-examine a number of so-called ‘market practices’. The intended readership of the book is tax lawyers, tax accountants, corporate lawyers, corporate advisors and finance directors who are involved in the process of the sale of a company. This edition contains an extended glossary, details of new investor relief schemes and changes in legislation as announced as at 15 September 2016.
Download or read book The Tax Schedule written by Eile Gibson and published by Spiramus Press Ltd. This book was released on with total page 577 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Tax Schedule explains the underlying rationale of the key provisions of the tax schedule, and provides updated model long-form and short-form warranties and tax indemnities. The purpose of the book is to explain and simplify issues for tax advisors involved in transactions of buying and selling companies and business, enabling negotiations between tax advisors to keep sight of the commercial reality of the transaction (a sale by a willing seller to a willing buyer). The purpose of the tax schedule is to determine where responsibilities and risks will lie following the completion of the transaction, as well as to re-examine a number of so-called ‘market practices’. The intended readership of the book is tax lawyers, tax accountants, corporate lawyers, corporate advisors and finance directors who are involved in the process of the sale of a company. Since the last edition, the UK has left the European Union (with little implications so far for tax schedules) and there have been two cases relating to the tax deed, relating tax warranties ( Nobahar-Cookson & ors v The Hut Group Ltd [2016] EWCA Civ 128 and Tesco UK Limited v Aircom Jersey 4 Limited and Aircom Global Operations Limited) and decided by the court of appeal, no less.
Download or read book The Law Times written by and published by . This book was released on 1864 with total page 636 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Tax written by Lynette Olivier and published by Siber Ink. This book was released on 2005 with total page 532 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition provides a thorough understanding of international income tax from a South African perspective. It deals in detail with: Controlled foreign companies; foreign dividends; double taxation agreements; exchange control restrictions; tax havens.
Download or read book Current Law written by Sweet & Maxwell, Limited and published by . This book was released on 2009-04-21 with total page 452 pages. Available in PDF, EPUB and Kindle. Book excerpt: The perfect combination - these two books together form a complete suite of upstream oil and gas agreements.
Download or read book The Weekly Notes written by Frederick Pollock and published by . This book was released on 1922 with total page 742 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Index to Canadian Legal Periodical Literature written by and published by . This book was released on 2005 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Nationality of Corporate Investors under International Investment Law written by Anil Yilmaz Vastardis and published by Bloomsbury Publishing. This book was released on 2020-10-01 with total page 323 pages. Available in PDF, EPUB and Kindle. Book excerpt: This monograph offers a detailed and distinctive analysis of corporate nationality under international investment law, covering the ICSID Convention and the investment treaty framework. It takes the reader back to the basics, threading through the concepts of jurisdiction, nationality, and corporate personality to give a clear context to the discussion of corporate nationality under international investment law, at a time when international investment is dominated by multinational business enterprises operating in a globalised economy. The book examines different understandings of corporate personality and nationality under a selection of jurisdictions and public international law. It also offers an in-depth analysis of approaches found in ICSID arbitral awards and in investment treaty practice, distilling the problematic areas and discussing the impacts of the areas of concern. It evaluates the techniques developed to address problems and puts forward suggestions for effective and balanced solutions to the questions of corporate nationality and personal scope of investment protection.
Download or read book Journals of the House of Lords written by Great Britain. Parliament. House of Lords and published by . This book was released on 1911 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt:
