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Taxation Of Cross Border Partnerships
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Book Synopsis Taxation of Cross-border Partnerships by : Jesper Barenfeld
Download or read book Taxation of Cross-border Partnerships written by Jesper Barenfeld and published by IBFD. This book was released on 2005 with total page 431 pages. Available in PDF, EPUB and Kindle. Book excerpt: Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."
Book Synopsis Understanding the Taxation of Partnerships by : Elizabeth Jameson Johnson
Download or read book Understanding the Taxation of Partnerships written by Elizabeth Jameson Johnson and published by . This book was released on 2017 with total page 994 pages. Available in PDF, EPUB and Kindle. Book excerpt: Understanding the Taxation of Partnerships is the only publication in Canada that provides a comprehensive analysis of tax issues affecting one of the most common forms of business organization. This publication provides in-depth analysis of the tax issues that must be considered when a partnership is used as a business or investment vehicle. There have been significant developments in the law and administrative practice since the last edition was published. The book has been updated to include: Changes in Canadian domestic law and international tax developments that have affected the use of partnerships in cross-border planning; The partnership anti-deferral rules; Amendments to certain anti-avoidance provisions and introduction of new anti-avoidance rules to address the use of partnerships in certain circumstances; Changes in the law that have affected planning by members of professional partnerships; Recent court cases and administrative developments that have implications for partnerships.
Book Synopsis Taxation of Partnerships and Partners Engaged in Cross-border Transactions Between the US and Germany, Entitlement of Partnerships to Treaty Benefits and Classification Conflicts by : Martin H. Seevers
Download or read book Taxation of Partnerships and Partners Engaged in Cross-border Transactions Between the US and Germany, Entitlement of Partnerships to Treaty Benefits and Classification Conflicts written by Martin H. Seevers and published by . This book was released on 2000 with total page 148 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Partnerships and Partners Engaged in International Transactions : Issues in Cross-border Transactions in Germany and the U.S. by : M.H. Seevers
Download or read book Taxation of Partnerships and Partners Engaged in International Transactions : Issues in Cross-border Transactions in Germany and the U.S. written by M.H. Seevers and published by . This book was released on 2002 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This study examines basic issues in the taxation of partners and partnerships engaged in international transactions. Special consideration is given to the tax consequences resulting from the use of partnerships in cross-border transactions between the USA and Germany, the entitlement of partnerships to treaty benefits, and classification conflicts.
Book Synopsis Structuring Cross-Border Transactions by : Mindy Herzfeld
Download or read book Structuring Cross-Border Transactions written by Mindy Herzfeld and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
Book Synopsis International Taxation of Cross-border Leasing Income by : Amar Mehta
Download or read book International Taxation of Cross-border Leasing Income written by Amar Mehta and published by IBFD. This book was released on 2005 with total page 307 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.
Book Synopsis EU Tax Disclosure Rules by : Haase, Florian
Download or read book EU Tax Disclosure Rules written by Haase, Florian and published by Edward Elgar Publishing. This book was released on 2021-08-27 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive, practical guide to the 6th amendment of Council Directive 2011/16/EU on administrative cooperation in the field of taxation (known as DAC6). Florian Haase offers insight and clarity into the mandatory reporting obligations imposed by DAC6 on intermediaries engaged in tax matters involving cross-border activities, and in some cases taxpayers themselves, as well as the characteristics or ‘hallmarks’ outlined in the Directive that trigger these obligations.
Book Synopsis Federal Taxation of Partnerships and Partners by : William S. McKee
Download or read book Federal Taxation of Partnerships and Partners written by William S. McKee and published by Warren Gorham & Lamont. This book was released on 1978 with total page 798 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Issues in International Partnership Taxation by : A. H. M. Daniels
Download or read book Issues in International Partnership Taxation written by A. H. M. Daniels and published by . This book was released on 1991 with total page 264 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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:
Book Synopsis Taxation of International Partnerships by : International Bureau of Fiscal Documentation
Download or read book Taxation of International Partnerships written by International Bureau of Fiscal Documentation and published by . This book was released on 2014 with total page 604 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of partnerships in an international context is undoubtedly one of the most complex areas of (international) tax law. It is also of great importance from a practical point of view. This is particularly due to two conflicting principles: some countries treat partnerships as taxable entities, while others treat them as opaque or transparent and only see the partners as taxpayers for tax purposes. This difference in approach can lead to double taxation as well as double non-taxation. In addition, specific problems can arise in the case of triangular situations.0The tax treatment of partnerships is so difficult and so important from a practical as well as an academic/theoretical point of view that the OECD, back in 1999, published an extensive report on this subject, the so-called “OECD Partnership Report”. This document set forth in great detail the view of the OECD with respect to the taxation of international partnerships from the perspective of the state of source as well as the state of residence. The Report contained some general remarks on the taxation of partnerships, but was mainly built on examples of specific cases and their tax treatment.0 In 2014, the OECD Partnership Report celebrates its 15th anniversary. Consequently, it is high time to investigate if and how the ideas of the OECD have been adopted by various jurisdictions. This book aims first to give a short introduction on the taxation of international partnerships in individual jurisdictions, and then to answer the problems posed in the examples in the Partnership Report from each jurisdictionþs perspective. To get the full picture, the jurisdictions covered include the economically most important EU Member States and other European countries like Switzerland, next to Australia, Brazil, China and the United States.
Book Synopsis Fundamentals of China Partnership Tax by : Robbie Chen
Download or read book Fundamentals of China Partnership Tax written by Robbie Chen and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: It has been about 23 years since the Partnership Enterprise Law was promulgated in China. Yet the tax rules only provide a general principle of the tax treatment of a partnership and that of partners, without providing detailed guidance on many technical issues. This leads to controversies and causes inconsistent interpretations and practices adopted by various local tax authorities. With many investment funds taking the form of a partnership and the opening of China's financial sector to foreign investors, the tax treatment of partnerships in China will attract more attention and debates, especially in an international tax context. This article introduces the current framework of partnership taxation in China and discusses how the tax treatment could be further complicated if a partnership has cross-border elements.
Book Synopsis Double non-taxation and the use of hybrid entities by : Leopoldo Parada
Download or read book Double non-taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.
Book Synopsis General Explanation of the Tax Reform Act of 1986 by :
Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1412 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Understanding the Taxation of Partnerships by : Peter E. McQuillan
Download or read book Understanding the Taxation of Partnerships written by Peter E. McQuillan and published by Don Mills, Ont. : CCH Canadian. This book was released on 1987 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Understanding the Taxation of Partnerships by : Jim Thomas
Download or read book Understanding the Taxation of Partnerships written by Jim Thomas and published by CCH Canadian, Limited. This book was released on 2006 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis U.S. International Tax Planning and Policy by : Samuel C. Thompson
Download or read book U.S. International Tax Planning and Policy written by Samuel C. Thompson and published by . This book was released on 2007 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: To access the 2010 Supplemental Materials, click here. This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions and addresses such issues as the U.S. taxation of a branch or U.S. subsidiary owned by a foreign corporation. Part III considers outbound transactions and deals with the U.S. taxation of foreign corporations controlled by U.S. persons. This part also addresses the rules regarding transfer pricing between commonly controlled entities, such as a U.S. parent corporation and its foreign subsidiary. Part IV focuses on cross-border mergers and acquisitions. Particular attention is given to the role of Section 367 on cross border reorganizations. The last sections of most chapters briefly discuss the manner in which South Africa, which has recently reformed its international tax system, addresses the issues presented in the chapter. From a tax planning standpoint, the U.S. tax advisor should have a basic understanding of the interface between the U.S. and foreign tax system involved in the transaction, and these discussions illustrate the interface between two sophisticated systems: the U.S. and South Africa.
