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Author : Philip F. Postlewaite
Publisher :
ISBN 13 :
Total Pages : 2542 pages
Book Rating : 4.F/5 ( download)
Download or read book Federal Income Taxation of Intellectual Properties and Intangible Assets written by Philip F. Postlewaite and published by . This book was released on 1998 with total page 2542 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : University of Denver. Bureau of Business and Social Research
Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.3/5 ( download)
Download or read book Taxation of Intangibles ... written by University of Denver. Bureau of Business and Social Research and published by . This book was released on 1940 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041123687
Total Pages : 360 pages
Book Rating : 4.0/5 (411 download)
Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 370941010X
Total Pages : 176 pages
Book Rating : 4.7/5 (94 download)
Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
Author : James Frank Zoller
Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.A/5 ( download)
Download or read book Taxation of Intangible Personal Property written by James Frank Zoller and published by . This book was released on 1915 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Virginia. State Tax Board
Publisher :
ISBN 13 :
Total Pages : 16 pages
Book Rating : 4.A/5 ( download)
Download or read book The Taxation of Intangibles in Virginia written by Virginia. State Tax Board and published by . This book was released on 1916 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Elizabeth King
Publisher : Springer Science & Business Media
ISBN 13 : 0306482185
Total Pages : 294 pages
Book Rating : 4.3/5 (64 download)
Download or read book Transfer Pricing and Valuation in Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2007-05-08 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
Author : Sophia Chen
Publisher : International Monetary Fund
ISBN 13 : 1498347835
Total Pages : 53 pages
Book Rating : 4.4/5 (983 download)
Download or read book The Tax-adjusted Q Model with Intangible Assets written by Sophia Chen and published by International Monetary Fund. This book was released on 2014-06-12 with total page 53 pages. Available in PDF, EPUB and Kindle. Book excerpt: We propose a tax-adjusted q model with physical and intangible assets and estimate it with a self-collected comprehensive database of intangible assets. The presence of intangibles changes the accounting and economic measures of q. We show that when tax changes are temporary, the q model can be estimated by adjusting for the firm’s intangible stock and intangible intensity. We estimate our model using temporary investment tax incentive policies in the United States in the early 2000s. When the q-model accounts for intangible assets, the estimated investment elasticity to tax incentives is generally larger than otherwise. It is also larger for intangible-intensive firms, and increases with firm size.
Author : Library of Congress. Division of Bibliography
Publisher :
ISBN 13 :
Total Pages : 16 pages
Book Rating : 4.F/5 ( download)
Download or read book A List of References on Taxation of Intangibles written by Library of Congress. Division of Bibliography and published by . This book was released on 1932 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : New Jersey. Commission on Taxation of Intangible Personal Property
Publisher :
ISBN 13 :
Total Pages : 136 pages
Book Rating : 4.:/5 (31 download)
Download or read book Report of the Commission on Taxation of Intangible Personal Property ... written by New Jersey. Commission on Taxation of Intangible Personal Property and published by . This book was released on 1945 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 : Governmental Research Institute (Saint Louis, Mo.)
Publisher :
ISBN 13 :
Total Pages : 124 pages
Book Rating : 4.3/5 (91 download)
Download or read book The Taxation of Intangibles in Missouri and the Other States written by Governmental Research Institute (Saint Louis, Mo.) and published by . This book was released on 1944 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michigan. State Tax Commission
Publisher :
ISBN 13 :
Total Pages : 20 pages
Book Rating : 4.3/5 (511 download)
Download or read book General Information Concerning the Intangibles Tax Law (Act 301, P.A. 1939) written by Michigan. State Tax Commission and published by . This book was released on 1939 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Governmental Research Institute (Saint Louis, Mo.)
Publisher :
ISBN 13 :
Total Pages : 12 pages
Book Rating : 4.:/5 (319 download)
Download or read book Constitutional Provisions Relating to the Taxation of Intangibles Should be Revised written by Governmental Research Institute (Saint Louis, Mo.) and published by . This book was released on 1943 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Ohio. Governor's Taxation Committee. Committee on Research
Publisher :
ISBN 13 :
Total Pages : 80 pages
Book Rating : 4.A/5 ( download)
Download or read book A Study of Low Rate Taxes on Intangible Property in Various States and Probable Yields of Such Taxes If Applied in Ohio written by Ohio. Governor's Taxation Committee. Committee on Research and published by . This book was released on 1930 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.3/5 (243 download)
Download or read book Intangible Property Taxes written by and published by . This book was released on 1992 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Björn Heidecke
Publisher : Springer
ISBN 13 : 9783319733319
Total Pages : 725 pages
Book Rating : 4.7/5 (333 download)
Download or read book Intangibles in the World of Transfer Pricing written by Björn Heidecke and published by Springer. This book was released on 2021-03-10 with total page 725 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.
