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Us Income Tax Treaties Permanent Establishments And Related Business Provisions
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Book Synopsis U.S. Income Tax Treaties — Permanent Establishments and Related Business Provisions by : Rod Donnelly
Download or read book U.S. Income Tax Treaties — Permanent Establishments and Related Business Provisions written by Rod Donnelly and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ...discusses U.S. income tax treaty provisions that relate to business income associated with permanent establishments, the specialized treatment of real estate, and international shipping and aircraft activities. In addition to discussing the nature of activity conducted by, and the type of income earned by, treaty country residents that may be taxed in the other treaty country, the Portfolio discusses the amount of income that may be taxed in the treaty country in which the income arises under the treaty rules governing business profits attributable to a permanent establishment, the specific treaty provisions governing real estate and international shipping and aircraft activities, and the treaty principles governing the allocation of income among associated enterprises. In particular, this Portfolio focuses on Articles 5 through 9 of the U.S. and OECD Model Income Tax Treaties, comparing the relevant 2006 and 2016 U.S. Model Income Tax Treaty articles and the corresponding articles in the OECD Model Income Tax Treaty through its 2017 update.
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 United States Tax Treaties by : United States
Download or read book United States Tax Treaties written by United States and published by Springer. This book was released on 1991-02-05 with total page 678 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Book Synopsis U.S. Income Tax Treaties by : Richard L. Doernberg
Download or read book U.S. Income Tax Treaties written by Richard L. Doernberg and published by . This book was released on 1999 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Book Synopsis Fundamentals of Permanent Establishments by : Robert L. Williams
Download or read book Fundamentals of Permanent Establishments written by Robert L. Williams and published by Kluwer Law International. This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.
Book Synopsis Explanation of Proposed Income Tax Treaty Between the United States and the Hungarian People's Republic by : United States. Congress. Joint Committee on Taxation
Download or read book Explanation of Proposed Income Tax Treaty Between the United States and the Hungarian People's Republic written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1979 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis United States Income Tax Treaties by : Klaus Vogel
Download or read book United States Income Tax Treaties written by Klaus Vogel and published by Springer. This book was released on 1989 with total page 1082 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive loose-leaf guide analysing United States income tax treaties. The commentary is divided into three parts providing general background information regarding income tax treaties and the model treaty process, commentary of the individual provisions of the US Model and of existing US treaties, appendices are included.
Book Synopsis U.S. Tax Treaties by : United States. Internal Revenue Service
Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and New Zealand by : United States. Congress. Joint Committee on Taxation
Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and New Zealand written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1983 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and Israel by : United States. Congress. Joint Committee on Taxation
Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and Israel written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1981 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Argentine Republic by : United States. Congress. Joint Committee on Taxation
Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Argentine Republic written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1981 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treaties written by United States and published by . This book was released on 1965 with total page 2368 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the People's Republic of China by :
Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the People's Republic of China written by and published by . This book was released on 1985 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Aspen Treatise for Introduction To United States International Taxation by : James R. Repetti
Download or read book Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
Book Synopsis Introduction to United States International Taxation by : James R. Repetti
Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
Book Synopsis Explanation of Proposed Income Tax Treaty Between the United States and Sweden by : United States. Congress. Senate. Committee on Foreign Relations
Download or read book Explanation of Proposed Income Tax Treaty Between the United States and Sweden written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1995 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Distributed to some depository libraries in microfiche.
Book Synopsis U.S. International Taxation by : Joel D. Kuntz
Download or read book U.S. International Taxation written by Joel D. Kuntz and published by . This book was released on 1991 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
