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International Double Taxation Of Interest
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Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Book Synopsis International Double Taxation by : United States. Congress. House. Committee on Ways and Means
Download or read book International Double Taxation written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1930 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transcript of Conference on International Double Taxation, Held in Washington, D.C., February 14, 1930, Under the Auspices of the United States Treasury Department by :
Download or read book Transcript of Conference on International Double Taxation, Held in Washington, D.C., February 14, 1930, Under the Auspices of the United States Treasury Department written by and published by . This book was released on 1930 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Double Taxation of Interest by : Sandra Martinho Fernandes
Download or read book International Double Taxation of Interest written by Sandra Martinho Fernandes and published by . This book was released on 2019 with total page 437 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Double Taxation Relief by : Mitchell Benedict Carroll
Download or read book Double Taxation Relief written by Mitchell Benedict Carroll and published by . This book was released on 1928 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Double Taxation of Interest by : Sandra Martinho Fernandes
Download or read book International Double Taxation of Interest written by Sandra Martinho Fernandes and published by . This book was released on 2019 with total page 437 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Advanced Introduction to International Tax Law by : Reuven S. Avi-Yonah
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 2015-02-27 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax. Systems of taxation deviate between jurisdictio
Book Synopsis Double Taxation and the League of Nations by : Sunita Jogarajan
Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 425 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Book Synopsis International Double Taxation by : Mogens Rasmussen
Download or read book International Double Taxation written by Mogens Rasmussen and published by Kluwer Law International B.V.. This book was released on 2011-01-01 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical introduction to the law of income and capital tax conventions based on the OECD Convention as well as selected legislation and case law. After an introduction, the chapters deal with the OECD Model, the UN Model, provisions which are not included in the model conventions (technical fees, professors, teachers and researchers, activities in connection with preliminary surveys, exploration or extraction of hydrocarbons, tax sparing, most-favoured nation clause, taxation of services), agreements containing a single provision concerning exchange of information, new wording of article 7 in the 2010-update of the OECD Model, and changes in the commentaries in the 2010-update of the OECD Model.
Book Synopsis Introduction to the Law of Double Taxation Conventions by : Michael Lang
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Book Synopsis International Tax Primer by : Brian J. Arnold
Download or read book International Tax Primer written by Brian J. Arnold and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 421 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition. Unquestionably, the most important development in international tax since the publication of the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition explores in detail both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. Also new to the fifth edition are sections dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: taxation of residents on foreign income and nonresidents on domestic income; mechanisms used to mitigate the risks to taxpayers of international double taxation; transfer pricing rules to prevent the avoidance of tax by multinational corporations; anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Author :Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs Publisher :Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre ISBN 13 : Total Pages :124 pages Book Rating :4.:/5 (318 download)
Book Synopsis International Tax Avoidance and Evasion by : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Download or read book International Tax Avoidance and Evasion written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre. This book was released on 1987 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of four related studies.
Book Synopsis Relief from International Income Taxation by : John Goodwin Herndon
Download or read book Relief from International Income Taxation written by John Goodwin Herndon and published by . This book was released on 1932 with total page 322 pages. Available in PDF, EPUB and Kindle. Book excerpt: History of the movement to prevent the double taxation of income internationally. Attempt to ascertain what specific recommendations could be made to the governments of the world which would have a reasonable change of being adopted and which, if adopted, would prevent international double taxation.
Book Synopsis Introduction to United States International Taxation by : James R. Repetti
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.
Book Synopsis International Tax Cooperation by : Luzius U. Cavelti
Download or read book International Tax Cooperation written by Luzius U. Cavelti and published by Stämpfli Verlag. This book was released on 2016-10-27 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Why is international cooperation on taxation so difficult to achieve? The problems in international taxation arise from a sovereignty conflict between the country in which the income originates (source country) and the country in which the recipient of the income resides (residence country). This book explores the equally valid sovereign tax claims of source and of residence countries and highlights the incompatibility of these concurrent tax claims. The resulting incoherence between source and residence countries distorts taxation of cross-border income to a point where it not only creates discriminations but challenges the fundamental principles of international taxation in itself. This is an essential dilemma of international tax policy. And yet, given the profound role the power to tax plays in exercising sovereignty, are governments able, or even willing, to eliminate this essential dilemma?
Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Book Synopsis Aspen Treatise for Introduction To United States International Taxation by : James R. Repetti
Download or read book Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 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 international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: 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 U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
