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Advance Tax Rulings And Principles Of Law
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Book Synopsis Advance Tax Rulings and Principles of Law by : Carlo Romano (juriste).)
Download or read book Advance Tax Rulings and Principles of Law written by Carlo Romano (juriste).) and published by IBFD. This book was released on 2002 with total page 579 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.
Book Synopsis Resolving Legal Uncertainty by : Yehonatan Givati
Download or read book Resolving Legal Uncertainty written by Yehonatan Givati and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings allow taxpayers to achieve certainty about the tax consequences of contemplated transactions, and are thus considered indispensable in the modern world of tax administration and compliance. After providing empirical evidence of tax law uncertainty, which should give rise to a demand for advance tax rulings, the article shows that advance tax rulings are in fact infrequently used. To explain this counterintuitive finding the article analyzes the taxpayers' strategic considerations when deciding whether to request an advance tax ruling. The strategic disadvantages of applying for an advance tax ruling are shown usually to outweigh the strategic advantages of such a request. Since the same strategic considerations apply when taxpayers decide whether to request an advance pricing agreement - a new procedure for resolving transfer pricing disputes - this analysis also explains why, despite considerable attention from scholars and practitioners in recent years, advance pricing agreements have been infrequently used, and are therefore unlikely to resolve the transfer pricing problem - probably the most significant problem in modern international taxation.
Book Synopsis Federal Taxation of Corporations and Corporate Transactions by : Steven Dean
Download or read book Federal Taxation of Corporations and Corporate Transactions written by Steven Dean and published by Aspen Publishing. This book was released on 2017-09-12 with total page 812 pages. Available in PDF, EPUB and Kindle. Book excerpt: This first edition of Federal Taxation of Corporations and Corporate Transactions provides a comprehensive examination of tax principles with a unique practice-oriented approach to help students become practice ready with skills that they have developed in a setting that reflects practice in the real world. The casebook introduces students not only to transactional tax practice and the federal tax penalty regime, but also to the rules of professional ethics and the specific rules that govern professionals who practice tax law. It features an array of Deal Downloads that breathe life into complex material, presenting high-profile transactions involving Amazon, Apple, Ford and others. This first edition will have a separately sold Client File supplement, which provides memoranda that require students to analyze the Deal Download transactions and to employ them as precedents to structure acquisitions, investments, and distributions for a hypothetical client. Key Benefits: Client files that are designed to help students learn the law in a practice-like setting. Extensive commentary about tax principles and cites to statutes, cases, regulations, and rulings that the students must study to fully learn the material. Chapter 9, where students will learn about the transaction that heralded the return of Steve Jobs to Apple in the 1990s and paved the way for the company’s subsequent dominant run. An examination of issues posed by classic cases, by focusing on the language of the underlying deal documents, and by learning how to solve clients’ problems before they are set in stone.
Book Synopsis Introducing an Advance Tax Ruling (ATR) Regime by : Mr.Christophe J Waerzeggers
Download or read book Introducing an Advance Tax Ruling (ATR) Regime written by Mr.Christophe J Waerzeggers and published by International Monetary Fund. This book was released on 2016-05-31 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Book Synopsis Advance Rulings on Tax Liability by : John Prebble QC
Download or read book Advance Rulings on Tax Liability written by John Prebble QC and published by . This book was released on 2015 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: As commercial transactions and tax law have both become more complex, tax practitioners have called for the establishment of procedures whereby taxpayers can find out in advance the official opinion of the revenue authorities as to the tax implications of their proposed transactions. If formally issued, such opinions should operate as rulings that are binding on the Crown even if they are later discovered to be wrong in law or if the Revenue changes its opinion. This book was written primarily for the purpose of describing and making recommendations for an advance rulings procedure that might be appropriate for New Zealand. It is also a comparative study of advance rulings procedures used in other countries, and in particular, the United States of America, Canada, and Sweden. It contains a draft statutory code. New Zealand adopted a “Determination” system for rulings in respect of loans and other financial arrangements and as a general “Rulings” system for rulings on other areas of the law. Both systems follow the principles that the author advocates.
Book Synopsis Principles of Tax Law by : David W. Williams
Download or read book Principles of Tax Law written by David W. Williams and published by . This book was released on 1996 with total page 491 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the principles underlying the major taxes, and offers an insight into how tax law has developed and is applied. This new edition ignores the detailed and frequently changing provisions found in practitioner texts, aiming to make the principles and
Author :Bert Alink Publisher :Institut für Finanz- und Steuerrecht, Universität Osnabrück ISBN 13 :3981489470 Total Pages :586 pages Book Rating :4.9/5 (814 download)
Book Synopsis Taxing German-Dutch Cross-Border Activities by : Bert Alink
Download or read book Taxing German-Dutch Cross-Border Activities written by Bert Alink and published by Institut für Finanz- und Steuerrecht, Universität Osnabrück. This book was released on 2015-02-04 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.
Book Synopsis Legitimate expectations in Luxembourg tax law by : Fatima Chaouche
Download or read book Legitimate expectations in Luxembourg tax law written by Fatima Chaouche and published by Éditions Larcier. This book was released on 2019-06-25 with total page 525 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the result of a 4-year research project conducted at the Faculty of Law of the University of Luxembourg. It explores the legal value and enforceability of tax circulars and tax rulings in Luxembourg domestic law in light of the principle of legitimate expectations and related principles. After studying the historical roots of both interpretative acts, this research questions the level of protection taxpayers enjoy when relying on circulars and tax rulings and contains a review of decades of administrative case-law to assess the judicial discourse on taxpayers’ rights to certainty. This book further investigates the case of circulars and tax rulings that contain interpretations of tax laws that are contrary to the law (contra legem) and builds upon the existing normative framework to introduce proposals addressing issues of uncertainty and inequality taxpayers are likely to suffer when relying on such interpretative acts. Prix Pierre Pescatore de la Faculté de Droit de Luxembourg (École doctorale de droit).
Book Synopsis Optimization of Organization And Legal Solutions Concerning Public Revenues And Expenditures in Public Interest by : Ewa Lotko
Download or read book Optimization of Organization And Legal Solutions Concerning Public Revenues And Expenditures in Public Interest written by Ewa Lotko and published by Wydawnictwo Temida 2. This book was released on 2018 with total page 794 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Tax Law by : Andrea Amatucci
Download or read book International Tax Law written by Andrea Amatucci and published by Kluwer Law International B.V.. This book was released on 2012-07-01 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: With a century of solid theory behind it, tax law confronts a new reality: the weakening of the tenacious link between the sovereignty of states and taxation. Yet it is to the continuity of certain themes and principles inherent in the various national tax systems that tax law scholarship continues to look, even as it develops new principles designed to meet the expanding processes of internationalization. This completely updated collection of essays offers an expert comparative analysis, conducted by a sample of the best international tax law scholars, of the fundamental theory of tax law and of the prospects in the near future of tax legislative systems. The emphasis falls naturally on tax theory, jurisprudence, and legislative development in the Member States of the European Union (particularly in Italy, Germany, and Spain), where the process of tax harmonization has been under way for many years. The effect of these processes, via the relevant tax treaties, on the tax systems of Japan and the United States provides a secondary emphasis. Practitioners and academics in tax law will find in this book an invaluable understanding of the challenges that tax law theory strives to meet at this crucial moment in economic history. The essays present a full and reliable exposition of the current theoretical approaches adopted by the various schools of thought in the field, as well as of the main contributions of jurisprudence.
Book Synopsis Legal Remedies in European Tax Law by : Pasquale Pistone
Download or read book Legal Remedies in European Tax Law written by Pasquale Pistone and published by IBFD. This book was released on 2009 with total page 573 pages. Available in PDF, EPUB and Kindle. Book excerpt: Until now the topic of legal remedies in European direct tax law has been significantly underexposed within the academic tax community. This book aims at filling this gap by providing the typical approaches to European tax law with a general vision on European law, and puts together theory and practice, but also includes contributions on selected relevant issues arising in the protection of taxpayers' rights.
Book Synopsis Davies Principles of Tax Law by : David W. Williams
Download or read book Davies Principles of Tax Law written by David W. Williams and published by . This book was released on 2000 with total page 455 pages. Available in PDF, EPUB and Kindle. Book excerpt: This revenue textbook seeks to make tax law understandable by demystifying the jargon, and should be useful to undergraduates, teachers of tax law and practitioners needing a simple guide to the subject. It concentrates on explaining the various principles underlying the major taxes, as well as offering an insight into how tax law has developed and is applied.
Book Synopsis The principle of non-discrimination in international and European tax law by : Niels Bammens
Download or read book The principle of non-discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.
Book Synopsis Financial Integration by : Marga Peeters
Download or read book Financial Integration written by Marga Peeters and published by Springer Science & Business Media. This book was released on 2013-09-21 with total page 230 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Arab upheaval and the world's biggest financial crisis after the Great Depression were almost simultaneous in their occurrence. The Mediterranean economies now face a dual challenge of a political and financial restructuring in the light of a shaky economic pedestal on which they stand. In light of this socio-political and economic shift in both inland and in world markets, this book offers a thorough analysis on problems, prospects and the way ahead for the financial integration of the South-Mediterranean region. Several perspectives on financial integration and policy recommendations are put forward from a leading group of researchers specializing on the Mediterranean region.
Author :American Bar Association. House of Delegates Publisher :American Bar Association ISBN 13 :9781590318737 Total Pages :216 pages Book Rating :4.3/5 (187 download)
Book Synopsis Model Rules of Professional Conduct by : American Bar Association. House of Delegates
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Book Synopsis Introducing an Advance Tax Ruling (ATR) Regime by : Mr.Christophe Waerzeggers
Download or read book Introducing an Advance Tax Ruling (ATR) Regime written by Mr.Christophe Waerzeggers and published by International Monetary Fund. This book was released on 2016-05-31 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Book Synopsis Interpretation of Tax Treaties under International Law by : F. A. Engelen
Download or read book Interpretation of Tax Treaties under International Law written by F. A. Engelen and published by IBFD. This book was released on 2004 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
