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Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 28 pages
Book Rating : 4.3/5 (126 download)
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:
Author : United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher :
ISBN 13 :
Total Pages : 1532 pages
Book Rating : 4.F/5 ( download)
Download or read book Legislative History of United States Tax Conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1532 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Jonathan Schwarz
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403526319
Total Pages : 870 pages
Book Rating : 4.4/5 (35 download)
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Author : United States
Publisher : Springer
ISBN 13 :
Total Pages : 678 pages
Book Rating : 4.F/5 ( download)
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.
Download or read book Canada-U.S. Tax Treaty written by and published by . This book was released on 1981 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher :
ISBN 13 :
Total Pages : 52 pages
Book Rating : 4.:/5 (3 download)
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Arvid Aage Skaar
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403520647
Total Pages : 957 pages
Book Rating : 4.4/5 (35 download)
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Author : United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight
Publisher :
ISBN 13 :
Total Pages : 182 pages
Book Rating : 4.0/5 (9 download)
Download or read book Income Tax Treaties written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1980 with total page 182 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 12 pages
Book Rating : 4.3/5 (126 download)
Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Richard L. Doernberg
Publisher :
ISBN 13 :
Total Pages : 444 pages
Book Rating : 4.:/5 (327 download)
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.
Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Author : Jon E. Bischel
Publisher :
ISBN 13 :
Total Pages : 1000 pages
Book Rating : 4.F/5 ( download)
Download or read book Income Tax Treaties written by Jon E. Bischel and published by . This book was released on 1978 with total page 1000 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of studies in the field of international taxation in United States bilateral tax treaties with other countries (the United Kingdom, France, Germany and Japan) as well as a description of structure and operation of tax treaties in general.
Author : United States
Publisher :
ISBN 13 :
Total Pages : 2368 pages
Book Rating : 4.F/5 ( download)
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:
Author : Fraser Milner Casgrain (Firm)
Publisher : CCH Canadian Limited
ISBN 13 : 9781554960026
Total Pages : 612 pages
Book Rating : 4.9/5 (6 download)
Download or read book Canada-U.S. Tax Treaty written by Fraser Milner Casgrain (Firm) and published by CCH Canadian Limited. This book was released on 2009 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Juan Angel Becerra
Publisher : IBFD
ISBN 13 : 9087220197
Total Pages : 299 pages
Book Rating : 4.0/5 (872 download)
Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Author : United States. Congress. Joint Committee on Taxation
Publisher :
ISBN 13 :
Total Pages : 24 pages
Book Rating : 4.:/5 (318 download)
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:
Author : Daniel Sandler
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041196536
Total Pages : 326 pages
Book Rating : 4.0/5 (411 download)
Download or read book Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
