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Fairness In International Taxation
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Book Synopsis Fairness in International Taxation by : J. Clifton Fleming
Download or read book Fairness in International Taxation written by J. Clifton Fleming and published by . This book was released on 2015 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the ability-to-pay fairness principle is a foundational element of American income tax policy, it has played a surprisingly small role in evaluating the U.S. international income tax regime. Perhaps this is because the application of the ability-to-pay concept to international income taxation is complicated by the presence of foreign taxpayers, by income earned through C corporations and by the claims of other governments to tax cross-border income. Nevertheless, it is possible, and indeed essential, to analyze international tax policy in terms of fairness. In this article, we extensively explore the international dimension of the ability-to-pay norm. We argue that this fairness criterion supports the conclusion that taxing worldwide income and ending the deferral privilege provides a tax regime that is superior to either the current U.S. international income tax system or the adoption of an exemption system.
Book Synopsis Global Tax Fairness by : Thomas Pogge
Download or read book Global Tax Fairness written by Thomas Pogge and published by Oxford University Press. This book was released on 2016-02-04 with total page 383 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses sixteen different reform proposals that are urgently needed to correct the fault lines in the international tax system as it exists today, and which deprive both developing and developed countries of critical tax resources. It offers clear and concrete ideas on how the reforms can be achieved and why they are important for a more just and equitable global system to prevail. The key to reducing the tax gap and consequent human rights deficit in poor countries is global financial transparency. Such transparency is essential to curbing illicit financial flows that drain less developed countries of capital and tax revenues, and are an impediment to sustainable development. A major break-through for financial transparency is now within reach. The policy reforms outlined in this book not only advance tax justice but also protect human rights by curtailing illegal activity and making available more resources for development. While the reforms are realistic they require both political and an informed and engaged civil society that can put pressure on governments and policy makers to act.
Book Synopsis Fairness in International Taxation by : Ira K Lindsay
Download or read book Fairness in International Taxation written by Ira K Lindsay and published by Hart Publishing. This book was released on 2024-04-04 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores the thorny normative issues raised by the changing landscape of international tax policy. Proposals for taxation of the digital economy and the OECD's BEPS framework promise fundamental changes in the international tax system. The book features perspectives from legal scholars, political theorists, and political philosophers on the design of a fair international tax system, considering both corporate and individual taxation. Contributors advance new theories of international tax justice, develop theoretically informed reform proposals and critique influential approaches to international tax reform. Key themes include justice in bilateral and multilateral international tax agreements, the taxation of cross-border workers, apportionment of tax revenue from multinational corporations, and the fairness of the international tax policy-making process. The book provides critical perspectives on leading international tax policy debates, analyses the intersection between international distributive justice and contemporary public policy, and proposes new ways to meet the demands of tax justice in a global context.
Book Synopsis The Proper Tax Base by : Yariv Brauner
Download or read book The Proper Tax Base written by Yariv Brauner and published by Kluwer Law International B.V.. This book was released on 2012-03-01 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world’s most respected international tax experts—including the late Paul McDaniel, in whose honor these essays were assembled—this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of “horizontal equity”; the international tax norm of “income source”; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.
Book Synopsis Fairness and International Taxation: Star-crossed Lovers?. by : F. Debelva
Download or read book Fairness and International Taxation: Star-crossed Lovers?. written by F. Debelva and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article demonstrates that despite its importance as a normative criterion for the international tax system, it is difficult to apply the standard of fairness for several reasons, including the lack of a general accepted definition thereof. Moreover, additional difficulties arise due to the nature of the tax system at both the national and international level. These difficulties are illustrated by benchmarking the recent developments at the international level against the normative criterion of fairness under several interpretations of this criterion.
Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh
Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Book Synopsis Fairness and International Taxation by : Filip Debelva
Download or read book Fairness and International Taxation written by Filip Debelva and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article demonstrates that despite its importance as a normative criterion for the international tax system, it is difficult to apply the standard of fairness for several reasons, including the lack of a general accepted definition thereof. Moreover, additional difficulties arise due to the nature of the tax system at both the national and international level. These difficulties are illustrated by benchmarking the recent developments at the international level against the normative criterion of fairness under several interpretations of this criterion.Full-text Paper.
Book Synopsis Proportionality and Fair Taxation by : João Dácio Rolim
Download or read book Proportionality and Fair Taxation written by João Dácio Rolim and published by Kluwer Law International. This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This in-depth coverage recognizes that tax law does not exist in isolation and reveals how tax law frequently overlaps with competition law, administrative law, environmental law, and constitutional law, and how principles from these areas of practice can affect the adjudication of tax cases. Proportionality and Fair Taxation is an important guide for all involved in tax law. Tax lawyers will find valuable insights that will help with both litigation and counselling whilst practitioners, academics, and policymakers will appreciate how the book reveals the extent to which an informed awareness of proportionality coupled with reasonableness is essential for the fair, consistent, and effective application of tax rules or measures. Order Proportionality and Fair Taxation by Joao Dacio Rolim for an in-depth discussion and practical guidance on the fundamental role of proportionality in tax matters
Download or read book Taxing the Rich written by Kenneth Scheve and published by Princeton University Press. This book was released on 2017-11-07 with total page 282 pages. Available in PDF, EPUB and Kindle. Book excerpt: A groundbreaking history of why governments do—and don't—tax the rich In today's social climate of acknowledged and growing inequality, why are there not greater efforts to tax the rich? In this wide-ranging and provocative book, Kenneth Scheve and David Stasavage ask when and why countries tax their wealthiest citizens—and their answers may surprise you. Taxing the Rich draws on unparalleled evidence from twenty countries over the last two centuries to provide the broadest and most in-depth history of progressive taxation available. Scheve and Stasavage explore the intellectual and political debates surrounding the taxation of the wealthy while also providing the most detailed examination to date of when taxes have been levied against the rich and when they haven't. Fairness in debates about taxing the rich has depended on different views of what it means to treat people as equals and whether taxing the rich advances or undermines this norm. Scheve and Stasavage argue that governments don't tax the rich just because inequality is high or rising—they do it when people believe that such taxes compensate for the state unfairly privileging the wealthy. Progressive taxation saw its heyday in the twentieth century, when compensatory arguments for taxing the rich focused on unequal sacrifice in mass warfare. Today, as technology gives rise to wars of more limited mobilization, such arguments are no longer persuasive. Taxing the Rich shows how the future of tax reform will depend on whether political and economic conditions allow for new compensatory arguments to be made.
Download or read book Virtual PE written by Reuven S. Avi-Yonah and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Congress may be about to enact the Marketplace Fairness Act of 2013, which overrules the Supreme Court's 1992 decision in Quill that banned states from requiring remote vendors to collect use tax on their behalf unless the vendor had a physical presence in the state. This paper explores the international tax implications of such a move given that the Permanent Establishment threshold is similar to the physical presence requirement that the Fairness Act seeks to abolish. It argues that the small business exception in the Fairness Act is a good model for international tax to follow in re-evaluating the PE threshold.
Book Synopsis Fairness in Practice by : Aaron James
Download or read book Fairness in Practice written by Aaron James and published by OUP USA. This book was released on 2012-04-13 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this book, the author argues that to achieve a fair global economy, there must be compensation of people harmed by their exposure to the global economy, but also equal division of the "gains of trade" across societies.
Book Synopsis Fairness and the Taxation of International Income by :
Download or read book Fairness and the Taxation of International Income written by and published by . This book was released on 1998 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: The relationship between the worldwide tax base and source taxation. An analysis of the relationship between normative principles and interindividual equity and between interindividual equity and the structure of the income tax in a unitary fiscal setting.
Book Synopsis Winning the Tax Wars by : Brigitte Alepin
Download or read book Winning the Tax Wars written by Brigitte Alepin and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past few decades, the concentration of wealth and property in the hands of a few has been facilitated by tax evasion, tax avoidance, and above all by tax competition. Fortunately, a determined move toward international cooperation among tax authorities is gathering its forces to do battle. This invaluable book shows how the globalization of trade, the digitization of the economy, tax competition between sovereign states, the erosion of the tax base, and the transfer of pro ts have all revealed the weaknesses of a traditional tax system that has reached its limits, and how numerous states and groups of states have joined efforts in creating a new international tax system designed to restore fairness and stability in the levying of taxes worldwide. Stemming from a 2016 conference initiated by the Canadian non-pro t organization TaxCOOP, convened by the World Bank and bringing together well-known taxation experts from prominent international organizations, the book presents outstanding contributions highlighting the impacts of tax competition and viable solutions. Among the issues and topics covered are the following: – electronic commerce and electronic money; – transfer pricing; – derivatives and hedge funds; – protecting tax whistle-blowers; – offshore tax investigations; – possibility of an international tax court; – impact of tax competition on developing countries; – carbon pricing; – tobacco taxation; and – effective taxation of the ultra-wealthy and their nancial capital. The chapters include details of country experiences and results, in some cases analyzed by key protagonists themselves. Collectively, the contributions take a giant step toward reinforcing the power of sovereign states in sectors such as the environment, education, and health. As an authoritative guide to increasing the level of transparency and accountability of private and public economic actors and restoring citizens’ trust in the fairness of our global governance systems, this peerless volume will be warmly welcomed by tax lawyers, taxation authorities, and interested academics worldwide.
Book Synopsis Tax and Fairness by : Deborah Russell
Download or read book Tax and Fairness written by Deborah Russell and published by Bridget Williams Books. This book was released on 2017-05-28 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt: The world has changed a lot in the last thirty years, but New Zealand’s tax system hasn’t. Since the 1980s New Zealand’s taxation policy has remained the same, despite substantial economic and social changes. The system may be familiar, but is it fair? Deborah Russell and Terry Baucher’s lively analysis shows why answers to this question cut to the heart of whether New Zealand can be considered an egalitarian country. Drawing on the latest evidence and using plain language, they explore thorny issues such as the taxation of housing, multinationals and inequality between generations. The remedies proposed in this short book will help change the way New Zealanders think about tax in the twenty-first century.
Book Synopsis Fairness : a Dire International Tax Standard with No Meaning by : I.J.J. Burgers
Download or read book Fairness : a Dire International Tax Standard with No Meaning written by I.J.J. Burgers and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In their discussions on corporate income tax systems the International Organizations (IOs) OECD, UN, IMF and World Bank, Supranational Organizations (SOs), Non-Governmental Organizations (NGOs), associations of practitioners and Governments often refer to the concept of fairness without proper definition of what in the context of their arguments is fairness and how the fairness can be achieved. The consequence is that fairness in taxation is a blurred concept. This article shows that fairness in taxation has an economical, juridical, philosophical and political perspective. Following the overview of these perspectives, this article calls for more research on global perceptions of fairness and for formulating an agenda for discussing this issue by IOs, SOs, NGOs and Governments.
Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux
Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2021-01-21 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book undertakes a fundamental review of the existing international system of taxing business profit. It steps back from the current political debates on how to combat profit shifting and how taxing rights over the profits of the digitalized economy should be allocated. Instead, it starts from first principles to ask how we should evaluate a tax on business profit—and whether there is any good rationale for such a tax in the first place. It then goes on to evaluate the existing system and a number of alternatives that have been proposed. It argues that the existing system is fundamentally flawed, and that there is a need for radical reform. The key conclusion from the analysis is that there would be significant gains from a reform that moved the system towards taxing profit in the country in which a business made its sales to third parties. That conclusion informs two proposals that are put forward in detail and evaluated: the Residual Profit Allocation by Income (RPAI) and the Destination-based Cash Flow Tax (DBCFT). The book is authored by group of economists and lawyers—the Oxford International Tax Group, chaired by Michael P. Devereux. It draws insights from both economics and law—including economic theory, empirical evidence on the impact of taxes, and an examination of practical issues of implementation—to assess the existing system and to consider fundamental reforms. This book will be useful to tax policy makers, tax professionals, academics, and anyone interested in tax policy.
Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux
Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
