Download or read book Corporate Residence and International Taxation written by Robert Couzin and published by IBFD. This book was released on 2002 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.
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 Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Download or read book Global Perspectives on E Commerce Taxation Law written by Dr Subhajit Basu and published by Ashgate Publishing, Ltd.. This book was released on 2013-01-28 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.
Download or read book Residence of Companies Under Tax Treaties and EC Law written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2009 with total page 969 pages. Available in PDF, EPUB and Kindle. Book excerpt: Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book Corporate Explorer written by Andrew Binns and published by John Wiley & Sons. This book was released on 2022-02-02 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporate Explorers Transform Disruption Into Opportunity With This Proven Framework Innovation used to be seen as a game best left to entrepreneurs, but now a new breed of corporate managers is flipping this logic on its head. These Corporate Explorers have the insight, resilience, and discipline to overcome the obstacles and build new ventures from inside even the largest organizations. Corporate Explorers are part entrepreneurs, using innovation disciplines to jump start cutting-edge ideas, and part change leaders, capable of creating support for investment. They see that corporations already own the ideas, resources, and—critically—the talent to build new ventures. Companies like Amazon, Microsoft, Bosch, LexisNexis, and Analog Devices enable managers to put these assets to use and gain an upper hand over startups that threaten to disrupt them. Corporate Explorer is a guidebook to the practices that enable these managers to go from idea into action. It demonstrates how success is not only possible but may offer entrenched companies better odds than venture-capital backed startups. This actionable and proven framework explains how managers can become successful corporate innovators; it includes tools to: Learn how to apply innovation practices with greater discipline Turn great ideas into a full-time job as an innovation leader Experiment with and scale original business models Transform innovation programs into a thriving source of new business Attract, retain, and motivate entrepreneurial talent Energize employees by creating a realistic way to innovate These lessons come from the trailblazers of corporate innovation—Andrew Binns (Change Logic), Charles O'Reilly (Stanford Graduate School of Business), and Michael Tushman (Harvard Business School)—who have decades of experience helping entrepreneurial-minded executives activate employees to become Corporate Explorers. Entrepreneurs take notice—it's time for Corporate Explorers to set the pace and chart the course for disruption.
Download or read book Tax and Government in the 21st Century written by Miranda Stewart and published by Cambridge University Press. This book was released on 2022-09-08 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: With an accessible style and clear structure, Miranda Stewart explains how taxation finances government in the twenty-first century, exploring tax law in its historical, economic, and social context. Today, democratic tax states face an array of challenges, including the changing nature of work, the digitalisation and globalisation of the economy, and rebuilding after the fiscal crisis of the COVID-19 pandemic. Stewart demonstrates the centrality of taxation for government budgets and explains key tax principles of equity, efficiency and administration. Presenting examples from a wide range of jurisdictions and international developments, Stewart shows how tax policy and law operate in our everyday lives, ranging from family and working life to taxing multinational enterprises in the global digital economy. Employing an interdisciplinary approach to the history and future of taxation law and policy, this is a valuable resource for legal scholars, practitioners and policy makers.
Download or read book Fixing U S International Taxation written by Daniel N. Shaviro and published by Oxford University Press. This book was released on 2014-01-08 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
Download or read book International Taxation in a Changing Landscape written by Jérôme Monsenego and published by Kluwer Law International B.V.. This book was released on 2019-05-31 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Prof. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax law, with a major focus on corporate taxation, an area to which Prof. Dr Bertil Wiman has dedicated most of his research. The book includes authoritative analyses by acknowledged experts on several key international tax topics, which illustrates the growing complexity of this area together with its rapid evolution. The book contains analyses of key international topics, such as: the tax challenges of the digitalisation of the economy; the resolution of international tax disputes; the principles for the taxation of corporations; EU tax law; transfer pricing; and tax treaty law. The depth of the essays contained in this book mirrors the importance of the contributions of Prof. Dr Bertil Wiman to the international tax community. It will also prove of great value to policymakers, tax practitioners and academics.
Download or read book Self employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Commentaries on the Law of Private Corporations written by Seymour Dwight Thompson and published by . This book was released on 1915 with total page 1060 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The American Corporation Cases written by Thomas Foster Withrow and published by . This book was released on 1881 with total page 718 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Guerrilla Tacos written by Wesley Avila and published by Ten Speed Press. This book was released on 2017-10-10 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: The definitive word on tacos from native Angeleno Wes Avila, who draws on his Mexican heritage as well as his time in the kitchens of some of the world's best restaurants to create taco perfection. In a town overrun with taco trucks, Wes Avila's Guerrilla Tacos has managed to win almost every accolade there is, from being crowned Best Taco Truck by LA Weekly to being called one of the best things to eat in Los Angeles by legendary food critic Jonathan Gold. Avila's approach stands out in a crowded field because it's unique: the 50 base recipes in this book are grounded in authenticity but never tied down to tradition. Wes uses ingredients like kurobata sausage and sea urchin, but his bestselling taco is made from the humble sweet potato. From basic building blocks to how to balance flavor and texture, with comic-inspired illustrations and stories throughout, Guerrilla Tacos is the final word on tacos from the streets of L.A.
Download or read book A Summary of the Law of Private Corporations written by Leslie Jay Tompkins and published by . This book was released on 1904 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book CDC Yellow Book 2020 written by Centers for Disease Control and Prevention (CDC) and published by . This book was released on 2019 with total page 721 pages. Available in PDF, EPUB and Kindle. Book excerpt: The definitive reference for travel medicine, updated for 2020 "A beloved travel must-have for the intrepid wanderer." -Publishers Weekly "A truly excellent and comprehensive resource." -Journal of Hospital Infection The CDC Yellow Book offers everything travelers and healthcare providers need to know for safe and healthy travel abroad. This 2020 edition includes: � Country-specific risk guidelines for yellow fever and malaria, including expert recommendations and 26 detailed, country-level maps � Detailed maps showing distribution of travel-related illnesses, including dengue, Japanese encephalitis, meningococcal meningitis, and schistosomiasis � Guidelines for self-treating common travel conditions, including altitude illness, jet lag, motion sickness, and travelers' diarrhea � Expert guidance on food and drink precautions to avoid illness, plus water-disinfection techniques for travel to remote destinations � Specialized guidelines for non-leisure travelers, study abroad, work-related travel, and travel to mass gatherings � Advice on medical tourism, complementary and integrative health approaches, and counterfeit drugs � Updated guidance for pre-travel consultations � Advice for obtaining healthcare abroad, including guidance on different types of travel insurance � Health insights around 15 popular tourist destinations and itineraries � Recommendations for traveling with infants and children � Advising travelers with specific needs, including those with chronic medical conditions or weakened immune systems, health care workers, humanitarian aid workers, long-term travelers and expatriates, and last-minute travelers � Considerations for newly arrived adoptees, immigrants, and refugees Long the most trusted book of its kind, the CDC Yellow Book is an essential resource in an ever-changing field -- and an ever-changing world.
