International Tax Aspects of Portfolio Investment

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Publisher :
ISBN 13 :
Total Pages : 12 pages
Book Rating : 4.:/5 (95 download)

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Book Synopsis International Tax Aspects of Portfolio Investment by : Jr. van Hoorn

Download or read book International Tax Aspects of Portfolio Investment written by Jr. van Hoorn and published by . This book was released on 1996 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author gives an introduction in the general tax aspects of portfolio investment: direct and indirect tax aspects, profits and withholding taxes at the domestic level, avoidance of double taxation, tax treaty law, tax harmonization.

International Tax Aspects of Sovereign Wealth Investors

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194339
Total Pages : 378 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Tax Aspects of Sovereign Wealth Investors by : Richard Snoeij

Download or read book International Tax Aspects of Sovereign Wealth Investors written by Richard Snoeij and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.

Taxation of International Portfolio Investment

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Publisher : IRPP
ISBN 13 : 9780886451233
Total Pages : 140 pages
Book Rating : 4.4/5 (512 download)

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Book Synopsis Taxation of International Portfolio Investment by : Donald J. S. Brean

Download or read book Taxation of International Portfolio Investment written by Donald J. S. Brean and published by IRPP. This book was released on 1991 with total page 140 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the key policy issues of particular relevance to Canada, but the analysis is relevant to policy issues facing many countries as a result growing financial and economic integration. This study explores key issues in the viability of national tax systems in a world of highly mobile capital.

Background and Issues Relating to the Taxation of Foreign Investment in the United States

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Publisher :
ISBN 13 :
Total Pages : 96 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Background and Issues Relating to the Taxation of Foreign Investment in the United States by : United States. Congress. House. Committee on Ways and Means

Download or read book Background and Issues Relating to the Taxation of Foreign Investment in the United States written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1990 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Taxation of Cross-Border Portfolio Investment Mutual Funds and Possible Tax Distortions

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264172882
Total Pages : 173 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Taxation of Cross-Border Portfolio Investment Mutual Funds and Possible Tax Distortions by : OECD

Download or read book Taxation of Cross-Border Portfolio Investment Mutual Funds and Possible Tax Distortions written by OECD and published by OECD Publishing. This book was released on 1999-05-04 with total page 173 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the taxation of cross-border portfolio investments by means of collective investment institutions. Possible tax distortions specific to the area of collective investment institutions are identified for a representative group of OECD countries.

Taxing Portfolio Income in Global Financial Markets

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Publisher : IBFD
ISBN 13 : 9076078440
Total Pages : 503 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis Taxing Portfolio Income in Global Financial Markets by : Doron Herman

Download or read book Taxing Portfolio Income in Global Financial Markets written by Doron Herman and published by IBFD. This book was released on 2002 with total page 503 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Studies in International Taxation

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Publisher : University of Chicago Press
ISBN 13 : 0226297039
Total Pages : 336 pages
Book Rating : 4.2/5 (262 download)

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Book Synopsis Studies in International Taxation by : Alberto Giovannini

Download or read book Studies in International Taxation written by Alberto Giovannini and published by University of Chicago Press. This book was released on 2007-12-01 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies. The contributors to this volume are Rosanne Altshuler, Alan J. Auerbach, Neil Bruce, Timothy Goodspeed, Roger H. Gordon, Harry Grubert, Bronwyn H. Hall, David Harris, Kevin Hassett, James R. Hines Jr., Roy D. Hogg, Joosung Jun, Jeffrey K. Mackie-Mason, Jack M. Mintz, Randall Morck, John Mutti, T. Scott Newlon, James M. Poterba, Joel Slemrod, Deborah Swenson, G. Peter Wilson, and Bernard Yeung.

US Taxation of Foreign Income

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Publisher : Peterson Institute
ISBN 13 : 0881325732
Total Pages : 340 pages
Book Rating : 4.8/5 (813 download)

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Book Synopsis US Taxation of Foreign Income by : Gary Clyde Hufbauer

Download or read book US Taxation of Foreign Income written by Gary Clyde Hufbauer and published by Peterson Institute. This book was released on 2007 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Carried Interest and Beyond

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Publisher :
ISBN 13 :
Total Pages : 64 pages
Book Rating : 4.:/5 (13 download)

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Book Synopsis Carried Interest and Beyond by : Young Ran (Christine) Kim

Download or read book Carried Interest and Beyond written by Young Ran (Christine) Kim and published by . This book was released on 2018 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: Private equity funds (PEFs) eliminate entity-level taxation by using pass-through entities. They further minimize their investors' tax liability by taking the position that profits distributed to both general partners (GPs) and limited partners (LPs) are passive portfolio investment income and taxed preferentially. The taxation of carried interest at low capital gains rates is likely the most infamous loophole. This article challenges such tax position and instead argues that the nature of PEF investment is active. PEFs seek to influence their portfolio companies to increase their value so that they actively manage the companies by acquiring at least 10% of their stock, which does not conceptually accord with portfolio investments. The proposed theory that PEFs are active is further supported by recent proposals on carried interest as well as cases and rulings holding that PEFs are involved in a “trade or business.”This article also considers international tax implications of the new theory: it switches the primary tax jurisdiction to levy tax on PEFs' cross-border income. This change may be justified for GPs who erode the tax base of a source country, but less justified for LPs because of their genuinely passive involvement, notwithstanding that LPs' tax-exempt or nonresident status enables GPs' abusive activities. Finally, determining the true nature of PEF investment and reforming PEF tax accordingly would increase worldwide revenue without significantly reducing the revenue of traditional residence countries, because the traditional residence countries, such as the United States, are also major source countries in the PEF industry.

Foreign Portfolio Investments in the United States

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Publisher :
ISBN 13 :
Total Pages : 58 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Foreign Portfolio Investments in the United States by : United States. Congress. Senate. Committee on Finance. Subcommittee on International Finance and Resources

Download or read book Foreign Portfolio Investments in the United States written by United States. Congress. Senate. Committee on Finance. Subcommittee on International Finance and Resources and published by . This book was released on 1976 with total page 58 pages. Available in PDF, EPUB and Kindle. Book excerpt:

International Tax Reform and the Inter-nation Allocation of Tax Revenue

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Publisher :
ISBN 13 :
Total Pages : 60 pages
Book Rating : 4.X/5 (2 download)

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Book Synopsis International Tax Reform and the Inter-nation Allocation of Tax Revenue by : A. J. Easson

Download or read book International Tax Reform and the Inter-nation Allocation of Tax Revenue written by A. J. Easson and published by . This book was released on 1991 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book looks critically at systems of international taxation and points out defects which could be rectified. It also looks ahead at possible directions for international taxation reform in preparation for the 21st century. It deals with: the search for an optimal system of international taxation; foreign direct investment and the multinational enterprise; neutrality and the efficient allocation of resources; inter-nation equity; transfer pricing; the treatment of intra-group payments, implementation.

A Pecking Order Theory of Capital Inflows and International Tax Principles

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Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 34 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis A Pecking Order Theory of Capital Inflows and International Tax Principles by : Assaf Razin

Download or read book A Pecking Order Theory of Capital Inflows and International Tax Principles written by Assaf Razin and published by International Monetary Fund. This book was released on 1996-04 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper highlights key sources of market failure in the context of international capital flows and provides guidelines for an efficient tax structure in the presence of capital market imperfections. It also emphasizes the efficiency of a non-uniform tax treatment of the various vehicles of international capital flows.

Tax Planning for Portfolio Investment Into the United States by Foreign Individuals

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Publisher :
ISBN 13 : 9781633593275
Total Pages : pages
Book Rating : 4.5/5 (932 download)

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Book Synopsis Tax Planning for Portfolio Investment Into the United States by Foreign Individuals by : Thomas St. G. Bissell

Download or read book Tax Planning for Portfolio Investment Into the United States by Foreign Individuals written by Thomas St. G. Bissell and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

United States Taxation of Foreign Investment Income

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Publisher :
ISBN 13 :
Total Pages : 204 pages
Book Rating : 4.:/5 (42 download)

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Book Synopsis United States Taxation of Foreign Investment Income by : Peggy B. Musgrave

Download or read book United States Taxation of Foreign Investment Income written by Peggy B. Musgrave and published by . This book was released on 1969 with total page 204 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Tax Competition for International Portfolio Capital Among Emerging Markets

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Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis Tax Competition for International Portfolio Capital Among Emerging Markets by : Bettina Reichl

Download or read book Tax Competition for International Portfolio Capital Among Emerging Markets written by Bettina Reichl and published by . This book was released on 1998 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Structuring Foreign Investment in US Real Estate

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Publisher :
ISBN 13 : 9789041128102
Total Pages : 1128 pages
Book Rating : 4.1/5 (281 download)

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Book Synopsis Structuring Foreign Investment in US Real Estate by : W. Donald Knight, Jr.

Download or read book Structuring Foreign Investment in US Real Estate written by W. Donald Knight, Jr. and published by . This book was released on 2009-01 with total page 1128 pages. Available in PDF, EPUB and Kindle. Book excerpt: Foreign investors and their American counterparts generally share the goal of minimizing income tax liabilities from their US real estate investments. This rather straightforward aim is complicated by the fact that non-US investors must be concerned not only with income taxes in the United States, but in their home country as well. What's more, the United States has a special income tax regime that's applicable to foreign persons. It's quickly evident to those involved that this is a complex area subject to new developments as the US Congress continually entertains new tax laws (and other statutes with relevant impact like the PATRIOT Act), the Internal Revenue Service promulgates regulations, rulings, announcements and interpretations, and the US courts issue opinions impacting the area. This timely and highly practical resource is designed to explore the considerations that are of unique concern to foreign individuals and entities making US real estate investments. To that end it details the US income, estate and gift tax aspects of inbound investment in US real property and the various structural techniques that may be employed to reduce or eliminate US tax liability under these domestic laws. This work's single-minded focus on real estate, the encyclopedic coverage of relevant tax considerations, and extensive materials on non-tax issues (asset protection, non-tax reporting, limits on foreign ownership of U.S, real estate, etc.) make it an essential resource for non-US investors and their advisers. Structuring Foreign Investment in US Real Estate covers: General rules for taxing inbound investments by non-US persons System for taxing operating income from foreign-owned US real estate Regime for taxing dispositions of US real estate by non-US owners Withholding obligations of purchasers of US real estate from non-US sellers Impact of tax treaty network on US taxation of inbound real estate investment Limitations on non-US ownership of US real estate Reporting obligations for non-US owners of US real estate Planning for acquisitions and dispositions of US real estate by non-US persons Estate and gift tax planning for foreign-owned US real estate This one-volume looseleaf answer questions, such as: How is direct foreign investment in US real estate taxed? How is portfolio investment in US real estate taxed? What are the seller's and buyer's tax obligations when foreign-owned US real estate changes hands? What planning techniques are available to non-US persons for holding and disposing of US real estate? What reporting obligations are associated with foreign ownership of US real estate? Are there limitations on the ability of non-US persons to own US real estate? What impact do tax treaties have on planning for foreign investment in US real estate? What state and local tax issues arise on inbound investment in US real estate? What estate and gift planning should be done for non-US owners of US real estate?

International Tax Policy and Double Tax Treaties

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Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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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.