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Author : International Tax Institute
Publisher :
ISBN 13 :
Total Pages : 313 pages
Book Rating : 4.:/5 (775 download)
Download or read book Latest Developments in U.S. Taxation of International Business written by International Tax Institute and published by . This book was released on 1978 with total page 313 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Andrew B. Lyon
Publisher : The Committee
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.:/5 (319 download)
Download or read book International Implications of U.S. Business Tax Reform written by Andrew B. Lyon and published by The Committee. This book was released on 1996 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the effects of tax law changes in the US and the potential for fundamental tax reform to alter the incentives facing businesses in their real and financial behaviour. The paper considers three different proposed reforms of the US tax system that would replace the income tax with a tax based on consumption. The proposals (a retail sales tax, the Hall-Rabushka flat tax, and the US personal expenditure tax), by exempting from taxation the marginal return to new investment, would make the US a very attractive location for multinational corporations relative to current law.
Author : D. Kevin Dolan
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (95 download)
Download or read book U.S. Taxation of International Mergers, Acquisitions, and Joint Ventures written by D. Kevin Dolan and published by . This book was released on 1995 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher :
ISBN 13 :
Total Pages : 12 pages
Book Rating : 4.:/5 (319 download)
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:
Author : Emanuel Kopp
Publisher : International Monetary Fund
ISBN 13 : 1498317049
Total Pages : 37 pages
Book Rating : 4.4/5 (983 download)
Download or read book U.S. Investment Since the Tax Cuts and Jobs Act of 2017 written by Emanuel Kopp and published by International Monetary Fund. This book was released on 2019-05-31 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
Author : National Research Council
Publisher : National Academies Press
ISBN 13 : 030906368X
Total Pages : 169 pages
Book Rating : 4.3/5 (9 download)
Download or read book Borderline Case written by National Research Council and published by National Academies Press. This book was released on 1998-02-05 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: The growing integration of world markets for capital and goods, coupled with the rise of instantaneous worldwide communication, has made identification of corporations as "American," "Dutch," or "Japanese" extremely difficult. Yet tax treatment does depend of where a firm is chartered. And, as Borderline Case documents, there is little doubt that tax rules for firms doing business in several nationsâ€"firms that account for more than three-quarters of corporate R&D spending in the United Statesâ€"have substantial effects on corporate decisionmaking and, ultimately, U.S. competitiveness. This book explores the impact of the U.S. tax code and its incentives on the international activities of U.S.- and foreign-based firms: basic research outlays, expenditures on product and process development, and plant and equipment investment. The authors include industry experts from large multinational firms in technology and pharmaceuticals, academic researchers who have explored the quantitative impact of tax provisions on R&D, and tax policy analysts who have examined international tax rules in the broader context of tax reform. These experts look at how corporate investment and R&D are shaped by specific tax provisions, such as the definition of taxable income, relative tax burdens on domestic and foreign business, taxation of earnings repatriated to the United States, deductibility of expenses of worldwide operations, and U.S. corporate taxes relative to other countries. The volume explores prescriptions and prospects for tax reform and reviews major reform proposals and their implications for the behavior of multinational business.
Author : Martin Feldstein
Publisher : University of Chicago Press
ISBN 13 : 0226241874
Total Pages : 338 pages
Book Rating : 4.2/5 (262 download)
Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
Author : Alberto Giovannini
Publisher : University of Chicago Press
ISBN 13 : 9780226297019
Total Pages : 348 pages
Book Rating : 4.2/5 (97 download)
Download or read book Studies in International Taxation written by Alberto Giovannini and published by University of Chicago Press. This book was released on 1993-09-15 with total page 348 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents research on how taxes affect the investment and financing decisions of multinationals. 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.
Author : John Abrahamson
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403510951
Total Pages : 448 pages
Book Rating : 4.4/5 (35 download)
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)
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.
Author : International Tax Institute
Publisher :
ISBN 13 :
Total Pages : 472 pages
Book Rating : 4.F/5 ( download)
Download or read book Current Developments in Taxation of International Business and Banking Transactions written by International Tax Institute and published by . This book was released on 1974 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: Selected papers and outlines of panelists at 1974 Public Technical Meetings in New York and Los Angelos of International Tax Institute, Inc.
Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403533641
Total Pages : 234 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Gary Clyde Hufbauer
Publisher : Peterson Institute
ISBN 13 :
Total Pages : 308 pages
Book Rating : 4.:/5 (318 download)
Download or read book U.S. Taxation of International Income written by Gary Clyde Hufbauer and published by Peterson Institute. This book was released on 1992 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: Assesses the impact of current tax policy on the competitiveness of American firms and considers and the need for new international norms to avoid transnational inconsistencies.
Author : Daniel N. Shaviro
Publisher : Oxford University Press, USA
ISBN 13 : 019935975X
Total Pages : 242 pages
Book Rating : 4.1/5 (993 download)
Download or read book Fixing U.S. International Taxation written by Daniel N. Shaviro and published by Oxford University Press, USA. This book was released on 2014-04 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Author : Joel D. Kuntz
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (91 download)
Download or read book U.S. International Taxation written by Joel D. Kuntz and published by . This book was released on 1991 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Ernest R. Larkins
Publisher : John Wiley & Sons
ISBN 13 : 0471482811
Total Pages : 456 pages
Book Rating : 4.4/5 (714 download)
Download or read book International Applications of U.S. Income Tax Law written by Ernest R. Larkins and published by John Wiley & Sons. This book was released on 2003-11-20 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
Author : Andreas Waltrich
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041168389
Total Pages : 362 pages
Book Rating : 4.0/5 (411 download)
Download or read book Cross-Border Taxation of Permanent Establishments written by Andreas Waltrich and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.
