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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 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.
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 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 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 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:
Book Synopsis Germany's Tax Treatment of Cross Border Royalty Payments to Non-residents by : Ruediger Urbahns
Download or read book Germany's Tax Treatment of Cross Border Royalty Payments to Non-residents written by Ruediger Urbahns and published by GRIN Verlag. This book was released on 2008 with total page 53 pages. Available in PDF, EPUB and Kindle. Book excerpt: Document from the year 2008 in the subject Business economics - Accounting and Taxes, grade: keine, 11 entries in the bibliography, language: English, abstract: This booklet is specifically addressed to foreign licensors and its tax advisors receiving licence income from German sources and which are faced or threatened with tax deduction in Germany. The intention of this book is to provide you with an adequate but hardly exhaustive understanding of the German tax consequences and also opportunities as a foreign licensor. After reading this book you should have a good understanding of you rights as taxpayer and should be able deal with the main tax issues as foreign licensor in Germany. Important Notice: The Tax Act of 2009 has changed large parts of the section 50a German Income Tax Act and thus the tax withholding procedure. In many cases a deduction of related expenses is now possible at least to a certain extent. Still not so, however, for royalty payments for which reason the domestic withholding tax rate has been reduced to 15% (plus solidarity surcharge), regardless if the foreign licensor is a corporation or other person.
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.
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 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 1991 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Understanding the Taxation of Partnerships by : CCH canadienne limitée
Download or read book Understanding the Taxation of Partnerships written by CCH canadienne limitée and published by Don Mills, Ont. : CCH Canadian. This book was released on 1982 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Corporate Taxation Through the Lens of Mergers & Acquisitions by : Samuel C. Thompson
Download or read book Corporate Taxation Through the Lens of Mergers & Acquisitions written by Samuel C. Thompson and published by . This book was released on 2005 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2010 Supplement for this book is available here. This book approaches the subject of Corporate Taxation through the prism of the Federal income tax treatment of taxable and tax-free mergers and acquisitions (M&A). Although the book discusses virtually every section of subchapter C of the Internal Revenue Code, which governs the tax treatment of corporations, the emphasis is placed on those provisions of subchapter C that have the most impact in M&A transactions. The book is structured for use both by students who have not previously been exposed to Corporate Tax and by those students who have. The book focuses principally on domestic M&A; however, because of the growing importance of cross-border M&A, the Federal income tax consequences of these transactions are also briefly examined. The book is divided into four parts. Part I contains an introduction to business tax principles, to basic corporate tax principles, and to the Federal income tax treatment of taxable and tax-free M&A. Part II focuses on taxable stock and asset acquisitions exploring in depth the Section 338 election and acquisitions of targets that are part of a consolidated group of corporations. Part III focuses on tax-free reorganizations, with the spotlight on acquisitive reorganizations. Part IV focuses on special topics, including acquisitions involving partnerships and S corporations; bankruptcy issues in M&A; and policy issues. "Thompson has written a comprehensive yet easy-to-follow book... I highly recommend Thompson's Corporate Taxation Through the Lens of Mergers and Acquisitions to any M&A tax professional. Thompson has done a superb job of translating the often incomprehensible tax code into language that a student or beginning tax professional can understand." -- The M&A Tax Report
Book Synopsis Switzerland in International Tax Law by : Xavier Oberson
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
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 Taxation of Financial Products, 2e by : Dearborn Financial Publishing
Download or read book Taxation of Financial Products, 2e written by Dearborn Financial Publishing and published by Kaplan Publishing. This book was released on 2002-04 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Taxation of Financial Products is designed for all financial services professionals.It explains the basics of selected financial products and their income tax treatment.Chapters focus on federal income tax basics, mutual funds, annuities, stocks, bonds, life insurance and qualified plans.The information provided is comprehensive and up to date with current tax laws and figures, as well as planning strategies."Taxation of Financial Products is written in plain English, and provides the financial services professional with the proper information needed to help meet clients' financial objectives. Material has been updated to reflect the changes made by the new distribution rules and the Tax Act of 2001, including updates to rules governing qualified plans, catch up contributions and simplification of required minimum distribution rules, and facts, figures, illustrations and examples have been updated. If you are taking this course for CE, the CE exam will automatically be added to your basket when selecting CE credit.Certain states require that a proctor/monitor supervise the exam taking process.
