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 International Aspects of U S Income Taxation written by John P. Steines, Jr. and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Income Taxation and International Mobility written by Jagdish N. Bhagwati and published by MIT Press. This book was released on 1989 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to "tax the brain drain."Today millions of people work in countries where they are not citizens. Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to tax the brain drain. The contributors, who include many of the leading theorists of international economics and public finance, look at how the difficult question of how horizontal equity is to be defined - between nationals at home and abroad or between nationals abroad and foreign citizens abroad - and tackle such questions as Should a country exercise income tax jurisdiction over its citizens abroad? If so, in what way? Is it practical to do so? The issues that these questions raise are complex, lying on the interface of politics, sociology, and economics. Income Taxation and International Mobility breaks significant new ground by analyzing these questions and building on the modern theory of optimal income taxation to examine the consequences of the possibility of outmigration on the appropriate exercise and design of income tax jurisdiction on those who live outside their native country. Theoretical analyses are presented in six chapters by the editors and by James Mirrlees, William Baumol, and Koichi Hamada. The well known tax law expert, Richard Pomp, examines the Philippines experience in taxing citizens abroad. The editors provide a substantial introduction that synthesizes the book's major analytical approaches and conclusions, and Richard Musgrave provides an insightful view of the issues in his Foreword.

Download or read book International Income Taxation written by Robert J. Peroni and published by CCH. This book was released on 2008 with total page 2356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.

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 International Income Taxation Code Regulations 2009 2010 written by Robert J. Peroni and published by Cch Incorporated. This book was released on 2009-07 with total page 3059 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished tax professors, this is a popular companion to international tax casebooks used in graduate courses offered by law and business schools. Unlike the multi-volume unabridged version, it concentrates solely on the essentials of international taxation. Updated annually with current legislation and regulations. Highly readable oversized page format with large type; Includes only the provisions related directly to the U.S. taxation of foreign and domestic entities that have income from sources outside the country; Annotated, digestible coverage.

Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.

Download or read book Global Taxation written by Philipp Genschel and published by Oxford University Press. This book was released on 2022 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global Taxation investigates the global transition to modern taxation from the 18th century to today. Modern taxation refers to the broad-based tax instruments that allowed for the emergence of big government as we know it today, including, most prominently, income taxes and general consumption taxes. The volume draws on a new historical dataset of tax introduction worldwide to map the global spread of modern taxes descriptively and to explore its correlates analytically. It makes four contributions to the literature. First, it corrects a pervasive Western bias in historical political economy and fiscal sociology. Most of this literature focuses heavily on the tax policy of advanced democracies in Europe. The chapters of this volume explore how far Western theories and insights travel to non-Western contexts. Second, the volume mitigates a recency bias in much of the macro-quantitative literature in comparative political economy and public finance. The chapters investigate whether insights travel across time from recent to more distant periods of observation. Third, the volume compensates for the substantive preoccupation of extant research with the personal income tax and the VAT by extending the analysis to other important tax instruments: the corporate income tax, the inheritance tax, non-VAT sales taxes, and social security contributions. Finally, the volume goes beyond the prevalent methodological nationalism in fiscal sociology and comparative political economy. It shows that non-sovereign tax introductions were common in colonial and imperial settings and compares analytically how the logic of these non-sovereign introductions differed from sovereign ones.

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 A Practical Guide to U S Taxation of International Transactions written by Robert Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

Download or read book International Income Taxation written by Robert J. Peroni and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2016-2017 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability. In this comprehensive and easy-to-use volume, Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country. Code and Regulations sections included are those deemed to be essential to International Tax teachers, students and practitioners.The 2016-2017 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2016. ABOUT THE EDITORS:This authoritative volume is edited by a team of highly regarded professors:- Robert J. Peroni, Coordinating Editor--Parker C. Fielder Regents Professor of Law, University of Texas- Richard C. Pugh, Contributing Editor--Distinguished Professor of Law, University of San Diego- Charles H. Gustafson, Contributing Editor--Professor of Law, Georgetown University

Download or read book Global Perspectives on Income Taxation Law written by Reuven Shlomo Avi-Yonah and published by Oxford University Press, USA. This book was released on 2011 with total page 202 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Global Perspectives on Income Taxation Law, Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class. It is arranged by subject matter in the order in which they are usually covered in U.S. tax law classes. The materials are drawn from a wide variety of countries, including developing countries.

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 249 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 International Income Taxation Code and Regulations Selected Sections 2019 2020 Edition written by Robert J. Peroni and published by . This book was released on 2019-06-22 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2019-2020 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability.

Download or read book International Company Taxation written by Ulrich Schreiber and published by Springer Science & Business Media. This book was released on 2013-01-30 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.

Download or read book International Income Taxation written by Robert J. Peroni and published by CCH Incorporated. This book was released on 2016-07-16 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2014-2015 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability

Download or read book Taxation of Inbound Investment written by W. Gordon Williamson and published by . This book was released on 1996 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: The purpose of this paper is to review the factors inherent in the Canadian income tax system that impact directly on inbound investment, including the Canadian withholding tax and thin capitalization provisions. This paper discusses the objectives of such provisions, as well as their impact on foreign investment and compares the Canadian income tax regime with respect to such factors to those of the UK, the USA, Germany, Australia and the Netherlands. Comparative study.