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The Double Taxation Of Dividend Income
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Author :Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation Publisher : ISBN 13 : Total Pages :16 pages Book Rating :4.A/5 ( download)
Book Synopsis The Double Taxation of Dividend Income by : Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation
Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation and published by . This book was released on 1953 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Elimination of the Double Tax on Dividends by : American Institute of Certified Public Accountants
Download or read book Elimination of the Double Tax on Dividends written by American Institute of Certified Public Accountants and published by . This book was released on 1976 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto
Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Book Synopsis International Double Taxation by : United States. Congress. House. Committee on Ways and Means
Download or read book International Double Taxation written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1930 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Book Synopsis Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective by : Erwin Nijkeuter
Download or read book Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective written by Erwin Nijkeuter and published by Kluwer Law International B.V.. This book was released on 2012-08-01 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Book Synopsis Transcript of Conference on International Double Taxation, Held in Washington, D.C., February 14, 1930, Under the Auspices of the United States Treasury Department by :
Download or read book Transcript of Conference on International Double Taxation, Held in Washington, D.C., February 14, 1930, Under the Auspices of the United States Treasury Department written by and published by . This book was released on 1930 with total page 144 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Comparison of US, UK and German corporate income tax systems with respect to dividend relief by : Benjamin Mahr
Download or read book Comparison of US, UK and German corporate income tax systems with respect to dividend relief written by Benjamin Mahr and published by GRIN Verlag. This book was released on 2007 with total page 58 pages. Available in PDF, EPUB and Kindle. Book excerpt: Essay from the year 2004 in the subject Business economics - Accounting and Taxes, grade: Distinction (83%), The University of Sydney (Faculty of Law), course: Comparative Corporate Taxation, language: English, abstract: This essay briefly describes the main different theoretical approaches (tax systems) designed to alleviate the double burden of corporation tax and shareholder income tax under Part 2. Parts 3- 5 explain how the problem of dividend double taxation was tried to be solved in the heterogeneous tax systems of the Germany, the UK and the US. However, the essay will not cover the different double tax avoiding treaties in force in those countries.
Book Synopsis Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States by : International Monetary Fund
Download or read book Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States written by International Monetary Fund and published by International Monetary Fund. This book was released on 1990-07-01 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.
Book Synopsis The Postwar Corporation Tax Structure by : United States. Dept. of the Treasury. Division of Tax Research
Download or read book The Postwar Corporation Tax Structure written by United States. Dept. of the Treasury. Division of Tax Research and published by . This book was released on 1946 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities by : Marjaana Helminen
Download or read book The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities written by Marjaana Helminen and published by Springer. This book was released on 1999-12-09 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: payments made under dividend-stripping arrangements fictitious profit distributions economic benefits in the context of transfer pricing returns on debt-equity hybrids interest payments in thin capitalisation situations and distributions following liquidation The analysis of each transaction refers to international tax law, including tax treaties, European tax law and the domestic tax law of Finland, Germany, Sweden and the United States. The comprehensive coverage and practical nature of The Dividend Concept in International Tax Law make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Book Synopsis Description of H.R. 5076 Relating to State Taxation of Foreign Source Corporate Income by : United States. Congress. House. Committee on Ways and Means
Download or read book Description of H.R. 5076 Relating to State Taxation of Foreign Source Corporate Income written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1980 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Must Corporate Income Be Taxed Twice? by : Charles E. McLure
Download or read book Must Corporate Income Be Taxed Twice? written by Charles E. McLure and published by Brookings Institution Press. This book was released on 1979 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries by : Peter Andrew Harris
Download or read book Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries written by Peter Andrew Harris and published by . This book was released on 1996 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: This ground-breaking book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, & they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies & inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms & finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing & could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation & many anti-avoidance measures would become superfluous. This extremely important book, based on prize-winning doctoral research, is destined to become a classic in the field. The acute perception & explication of theories underpinning international taxation make it essential reading.
Book Synopsis The Taxation of Corporations and Shareholders by : Martin Norr
Download or read book The Taxation of Corporations and Shareholders written by Martin Norr and published by Springer Science & Business Media. This book was released on 2013-06-29 with total page 222 pages. Available in PDF, EPUB and Kindle. Book excerpt: This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.
Book Synopsis International Double Taxation by : Mogens Rasmussen
Download or read book International Double Taxation written by Mogens Rasmussen and published by Kluwer Law International B.V.. This book was released on 2011-01-01 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical introduction to the law of income and capital tax conventions based on the OECD Convention as well as selected legislation and case law. After an introduction, the chapters deal with the OECD Model, the UN Model, provisions which are not included in the model conventions (technical fees, professors, teachers and researchers, activities in connection with preliminary surveys, exploration or extraction of hydrocarbons, tax sparing, most-favoured nation clause, taxation of services), agreements containing a single provision concerning exchange of information, new wording of article 7 in the 2010-update of the OECD Model, and changes in the commentaries in the 2010-update of the OECD Model.
Book Synopsis Once is Enough by : Charles E. McLure
Download or read book Once is Enough written by Charles E. McLure and published by . This book was released on 1977 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt:
