Read Books Online and Download eBooks, EPub, PDF, Mobi, Kindle, Text Full Free.
Taxation Of Cross Border Portfolio Investment
Download Taxation Of Cross Border Portfolio Investment full books in PDF, epub, and Kindle. Read online Taxation Of Cross Border Portfolio Investment ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
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 172 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.
Book Synopsis Taxation of Cross-border Portfolio Investment by :
Download or read book Taxation of Cross-border Portfolio Investment written by and published by Org. for Economic Cooperation & Development. This book was released on 1999 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt: The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institution
Book Synopsis Taxation of cross-border portfolio investment by : Organisation for Economic Co-operation and Development
Download or read book Taxation of cross-border portfolio investment written by Organisation for Economic Co-operation and Development and published by . This book was released on 1999 with total page 173 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Income from Domestic and Cross-border Collective Investment by : Andreas Oestreicher
Download or read book Taxation of Income from Domestic and Cross-border Collective Investment written by Andreas Oestreicher and published by Springer Science & Business Media. This book was released on 2013-07-30 with total page 170 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.
Book Synopsis Cross-Border Taxation of Permanent Establishments by : Andreas Waltrich
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.
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 Cross-Border Investment Withholding Tax by : Ross K. McGill
Download or read book Cross-Border Investment Withholding Tax written by Ross K. McGill and published by Springer Nature. This book was released on 2023-06-12 with total page 405 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a clear and concise explanation of withholding tax and how to leverage best practice to generate improved investment performance. It gives practical guidance to financial service firms and investors to help them understand the issues involved, trends and practicalities of maximizing returns on investment. Most of the $200 billion of withholding tax lost by investors annually is due to lack of awareness and not asking the right questions of their brokers and custodian banks. Financial institutions are also increasingly being held to a higher standard by investors for provision of withholding tax services because of the impact it can have on portfolio performance. This book seeks to raise awareness of the issues and provide more detail about how the system works and what challenges and changes readers should expect in the future.
Book Synopsis The Cross-Border Family Wealth Guide by : Andrew Fisher
Download or read book The Cross-Border Family Wealth Guide written by Andrew Fisher and published by John Wiley & Sons. This book was released on 2017-01-03 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Make sense of international personal finance with expat-specific expert advice The Cross-Border Family Wealth Guide is the long-awaited financial handbook for cross border families, with expert insight from a financial advisor who specializes in expat issues. Whether you're an American living abroad, or foreign-born and living in the U.S., this book demystifies the complex issues surrounding the worldwide tax system, international information reporting, sensible investments, international real estate, and retirement planning. When your wealth crosses international borders, managing even the most mundane financial affairs can become wrought with time-consuming complexity; moving money, opening accounts, dealing with currency risks and translation, and setting up investments suddenly involves a whole new set of rules and regulations. Your 401(k), IRA, or annuity must be handled properly to retain certain tax benefits, and retirement planning takes on a brand new dimension of difficulty. This book shows you how to navigate the maze to make sure your money keeps working for you. Real world examples illustrate solutions to common problems, and real, actionable advice gives you a solid plan for your next steps. While personal finance management is rarely simple, the recent crackdown on tax havens and increased tax collection vigilance has made things even more difficult for cross border families. This book answers your questions, and shines a light on the way forward to long-term financial security for international families. Navigate the complexities of international taxation Get specific guidance on retirement planning Make sense of how real estate fits into your financial picture Invest appropriately to maximize growth for the future Manage your assets and tax benefits across borders With the right know-how, cross border professionals can make sensible investment and financial planning decisions, but credible guidance is rare and difficult to find. Simple and practical, with targeted advice, The Cross-Border Family Wealth Guide is the international family's solution for avoiding financial confusion.
Book Synopsis Taxation of Investment Funds in the European Union by : Tomi Viitala
Download or read book Taxation of Investment Funds in the European Union written by Tomi Viitala and published by IBFD. This book was released on 2005 with total page 427 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
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.
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 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:
Book Synopsis Puzzles Over International Taxation of Cross Border Flows of Capital Income by : John Whalley
Download or read book Puzzles Over International Taxation of Cross Border Flows of Capital Income written by John Whalley and published by . This book was released on 2001 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: I discuss the tax treatment of transborder capital income, focussing on prevailing arrangements rather than de novo design of optimal tax arrangements. These comprise unilateral reliefs from double taxation under credit or exemption systems, and treaty reliefs (largely following the OECD model treaty) which jointly lower withholding tax rates on interest, dividends, and royalties in both host and source countries. I suggest that these arrangements involve both seemingly non-strategic unilateral actions and cooperative arrangements which are difficult to reconcile both with tax competition literature and with national interest. I pose four puzzles in this regard. The first is that from a national welfare point of view, the unilateral reliefs in use seem inferior to no relief since with competitive markets investors equate the private return on investments at home and abroad, while tax revenues largely accrue to the foreign government. Private returns are equated, but national returns are not. The second is that tax treaties only have lump sum effects between national governments if the more common credit arrangements of unilateral reliefs apply and if tax rates are similar in host and source countries (approximately the OECD situation). This raises the issue of why governments negotiate them. The third is the sharp contrast to international treaty arrangements for goods flows under the WTO; and the fourth is the absence of side payments in tax treaties. The picture emerging is that making sense of present arrangements from a national welfare point of view and in terms of efficient instrument design seems difficult. The gap relative to optimal tax considerations also seems large.
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 Offshore Tax Strategies by : Vernon K. Jacobs
Download or read book Offshore Tax Strategies written by Vernon K. Jacobs and published by Offshore Press, Inc.. This book was released on 2006-08 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: Offshore Tax Strategies by Vernon Jacobs and Richard Duke is a concise, plain English introduction to the U.S. tax rules for cross border investments, foreign trusts, foreign corportions and other foreign entities owned by U.S. citizens or residents. Jacobs is a CPA with a focus on international tax law and Duke is an attorney with a concentration in international tax law.
Book Synopsis Capital Mobility and Tax Competition by : Clemens Fuest
Download or read book Capital Mobility and Tax Competition written by Clemens Fuest and published by Now Publishers Inc. This book was released on 2005 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition and coordination is one of the most pressing issues for tax authorities in modern economies, but it is a highly controversial subject. Some argue that tax competition is beneficial by forcing governments to impose efficient tax prices on residents for the provision of public services. Further, some argue that tax competition is also beneficial by limiting the power of governments to levy taxes. Others take a different view - in a world without coordinated tax policies, governments choose sub-optimal levels of public services financed by inefficient taxes that are either too high or too low by ignoring spillovers imposed on other jurisdictions. Capital Mobility and Tax Competition draws out the most important issues of uncoordinated tax policy at the international level for cross-border transactions. The discussion focuses on mobile tax bases, specifically in relation to investment and financial transactions. The main issue for consideration in this survey is whether taxation of income, specifically capital income will survive, how border crossing investment is taxed relative to domestic investment, and whether welfare gains can be achieved through international tax coordination. This survey derives some of the key results on the taxation of international investment in variants of one model of multinational investment. Finally, the authors emphasize the problem of tax competition and financial arbitrage, an issue which is somewhat neglected in the existing survey literature.
Book Synopsis Reforming Capital Income Taxation by : Horst Siebert
Download or read book Reforming Capital Income Taxation written by Horst Siebert and published by . This book was released on 2019-09-13 with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book surveys the theoretical issues that characterize the problem of reforming capital income taxes in an open economy. It explores the tax incentives and disincentives to investment in an open economy framework allowing cross-border portfolio and direct investment.
