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Author :
Publisher :
ISBN 13 :
Total Pages : 386 pages
Book Rating : 4.F/5 ( download)
Download or read book Basic Rules of U.S. Taxation for Inbound Foreign Investment written by and published by . This book was released on 1991 with total page 386 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Philip F. Postlewaite
Publisher :
ISBN 13 : 9781531011161
Total Pages : pages
Book Rating : 4.0/5 (111 download)
Download or read book United States International Taxation written by Philip F. Postlewaite and published by . This book was released on 2022-02 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : W. Gordon Williamson
Publisher :
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.:/5 (31 download)
Download or read book Taxation of Inbound Investment written by W. Gordon Williamson and published by . This book was released on 1996 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: The purpose of this paper is to review the factors inherent in the Canadian income tax system that impact directly on inbound investment, including the Canadian withholding tax and thin capitalization provisions. This paper discusses the objectives of such provisions, as well as their impact on foreign investment and compares the Canadian income tax regime with respect to such factors to those of the UK, the USA, Germany, Australia and the Netherlands. Comparative study.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264038388
Total Pages : 191 pages
Book Rating : 4.2/5 (64 download)
Download or read book OECD Tax Policy Studies Tax Effects on Foreign Direct Investment Recent Evidence and Policy Analysis written by OECD and published by OECD Publishing. This book was released on 2007-12-20 with total page 191 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication reports the results of a project examining taxation and foreign direct investment (FDI).
Author : United States. Department of the Treasury
Publisher :
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.:/5 (319 download)
Download or read book Taxation of Foreign Investment in U.S. Real Estate written by United States. Department of the Treasury and published by . This book was released on 1979 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Mr. Alexander D Klemm
Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 30 pages
Book Rating : 4.4/5 (2 download)
Download or read book The Impact of the Tax Cuts and Jobs Act on Foreign Investment in the United States written by Mr. Alexander D Klemm and published by International Monetary Fund. This book was released on 2022-05-06 with total page 30 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US companies. We first model effective marginal and average tax rates (EMTRs and EATRs) by country, industry, and method of finance, and then use those tax rates to calculate the tax semi-elasticities of inbound FDI and PPE investment. We find that both PPE investment and FDI financed with retained earnings responded positively to the TCJA reform, but FDI financed with new equity or debt did not. In country-level PPE regressions, inclusion of macroeconomic controls renders tax rate coefficients insignificant, suggesting that the increase in PPE investment after TCJA was driven by general economic growth. In regressions of FDI financed with retained earnings, however, tax coefficients were robust to inclusion of macroeconomic controls. As the literature predicts, EATRs have a greater impact on cross-border investment than EMTRs. Country-by-industry regressions showed a larger effect of taxes on PPE investment than aggregate country-level regressions, but industry-level tax rates appear to have no effect on earnings retention.
Author : W. Donald Knight, Jr.
Publisher :
ISBN 13 : 9789041128102
Total Pages : 1128 pages
Book Rating : 4.1/5 (281 download)
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?
Author : W. Gordon Williamson
Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.:/5 (823 download)
Download or read book Taxation of Inbound Investment written by W. Gordon Williamson and published by . This book was released on 1997 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Karl P Sauvant
Publisher : Oxford University Press
ISBN 13 : 0199745188
Total Pages : 795 pages
Book Rating : 4.1/5 (997 download)
Download or read book The Effect of Treaties on Foreign Direct Investment written by Karl P Sauvant and published by Oxford University Press. This book was released on 2009-03-27 with total page 795 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Author : John Prebble
Publisher :
ISBN 13 :
Total Pages : 216 pages
Book Rating : 4.0/5 ( download)
Download or read book Taxing Offshore Investment Income written by John Prebble and published by . This book was released on 2006 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: An international panel of experts address the design and operation of offshore investment fund regimes. The book is comparative, dealing with topics issue-by-issue rather than country-by-country. (Legal Reference/Law)
Author : David Herzig
Publisher :
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.:/5 (13 download)
Download or read book Elective Taxation on Inbound Real Estate Investment written by David Herzig and published by . This book was released on 2016 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident must pay tax on the capital gain from the sale of U.S. real property or rights in U.S. real property, as well as on the sale of shares in non-publicly held domestic corporations that hold significant U.S. real property assets. The United States imposes a withholding liability on the purchaser based on a percentage of the purchase price. Moreover, by owning U.S. real property, foreign investors are subject to Internal Revenue Service (IRS) investigatory powers. Because of these rules, foreign investors spend significant resources to structure investment in U.S. real property assets to avoid being deemed an owner of the underlying real property for taxation purposes. This has rendered the underlying statute, the Foreign Investment in Real Property Act of 1980 (FIRPTA), elective.This electivity results in the United States exhibiting tax haven characteristics for inbound real estate investments. Rather than tightening the rules to eliminate this friction, Congress has recently proposed even looser requirements. The resulting narrative by practitioners and policy makers is that FIRPTA should be eliminated. The United States currently needs more, not less, collection of taxation. The fact that FIRPTA is either easily arbitraged or not properly collected should not result in the repeal.This Article proposes a new way of addressing FIRPTA by expanding the use of reporting requirements to capture the leakage and provide a mechanism for effectively eliminating the use of structuring to avoid the tax. Through the introduction of systems recently employed in the Foreign Account Tax Compliance Act (FATCA) regime, Congress can implement an effective penalty structure to ensure proper collection of taxation and achieve the stated goal of FIRPTA -- an equal tax burden independent of the status of the investor. The goal of the proposal is to have a more cohesive and coherent FIRPTA regime by replacing a gross income tax regime with a net income tax regime with a backup withholding. Given the United States' position as a market leader in a limited market, there should be a more aggressive tax collection stance taken. The U.S. real property market is relatively inelastic as compared to equities; thus, an aggressive U.S. position will not have much if any downside.
Author : Jack M. Mintz
Publisher : MIT Press
ISBN 13 : 0262014491
Total Pages : 203 pages
Book Rating : 4.2/5 (62 download)
Download or read book The The Indirect Side of Direct Investment written by Jack M. Mintz and published by MIT Press. This book was released on 2010-08-06 with total page 203 pages. Available in PDF, EPUB and Kindle. Book excerpt: Drawing on a unique data set (MiDi) on German multinationals provided by the Deutsche Bundesbank in Frankfurt, Mintz and Weichenrieder confirm the prevalence of indirect financing structures for both outbound and inbound German investment. They find evidence of "treaty shopping!' to avoid withholding taxes (using a third country with more favorable tax rates as a conduit through which to route investments) and of "debt shifting." --
Author : Canada. Department of Finance. Technical Committee on Business Taxation
Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.:/5 (32 download)
Download or read book Taxation of Inbound Investment written by Canada. Department of Finance. Technical Committee on Business Taxation and published by . This book was released on 1996 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 : B. G. Dahlby
Publisher :
ISBN 13 : 9781100116150
Total Pages : pages
Book Rating : 4.1/5 (161 download)
Download or read book Taxation of Inbound Direct Investment written by B. G. Dahlby and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Gunadi
Publisher :
ISBN 13 :
Total Pages : 272 pages
Book Rating : 4.:/5 (318 download)
Download or read book Taxation of Inbound Investment in Indonesia written by Gunadi and published by . This book was released on 1992 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Denis A. Kleinfeld
Publisher : Practising Law Inst
ISBN 13 : 9780872241282
Total Pages : 1735 pages
Book Rating : 4.2/5 (412 download)
Download or read book Langer on Practical International Tax Planning: Focus on tax planning written by Denis A. Kleinfeld and published by Practising Law Inst. This book was released on 2000 with total page 1735 pages. Available in PDF, EPUB and Kindle. Book excerpt: Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.
