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Source Versus Residence
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Book Synopsis Source Versus Residence by : Michael Lang
Download or read book Source Versus Residence written by Michael Lang and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Download or read book Source Versus Residence written by and published by . This book was released on 2007 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Recently, issues of international taxation have also been analysed from a New Economic Geography perspective. These discussions show that agglomerative forces play a non negligible role. In the paper, we introduce explicitly taxation into a Footloose Capital Model and compare implications of taxation according to the residence principle and the source principle from a New Economic Geography perspective. We confirm that agglomerative effects change the results substantially compared to the standard analysis and that the two taxation principles have different implications for industry agglomeration. (author's abstract).
Book Synopsis Source-based Versus Residence-based Taxes in a Dynamic Model by :
Download or read book Source-based Versus Residence-based Taxes in a Dynamic Model written by and published by . This book was released on 1996 with total page 11 pages. Available in PDF, EPUB and Kindle. Book excerpt: Macro-economical paper comparing source based taxation with residence based taxation in the context of the inefficiencies caused by tax competition between states. The paper concludes in favour of source based taxation in view of the lower welfare costs this gives rise to.
Book Synopsis Source Versus Residence by : Michael Lang/ Pasquale Pistone / Josef Schuch / Claus Staringer
Download or read book Source Versus Residence written by Michael Lang/ Pasquale Pistone / Josef Schuch / Claus Staringer and published by . This book was released on 2008-09-01 with total page 404 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Model Tax Convention, other treaties, and the bilateral treaties drafted in accordance with these models allocate the taxing rights between the state of source and the state of residence. The allocation rules for income taxation are determined by Articles 6 to 21 of the OECD Model Convention. Courts, tax administrations, and practitioners have to deal with a growing number of interpretation and application problems in connection with these rules. The publication at hand provides an analysis of the allocation rules of the OECD Model Tax Convention and their equivalents in bilateral tax treaties and proposes possible alternatives.
Book Synopsis Source as a Solution to Residence by : Adam H. Rosenzweig
Download or read book Source as a Solution to Residence written by Adam H. Rosenzweig and published by . This book was released on 2015 with total page 63 pages. Available in PDF, EPUB and Kindle. Book excerpt: The choice between source-based and residence-based taxation has defined the terms of the debate for the international tax regime since its inception in the early 1900's. The thesis of this Article is that the construct of source and residence as two competing and irreconcilable doctrines is largely incorrect as a legal matter. Rather, both source rules and residence rules can and should be thought of solely as instrumental tools to divide taxing authority in a globalized world with mobile capital. Under this approach, there is no reason why “source” rules as a doctrinal matter need to be used only for “source” taxation as an economic matter, or that “residence” rules as a doctrinal matter need be used for “residence” taxation as an economic matter. Instead, the source rules as a doctrinal matter can actually be used to solve the problems of the residence rules as a doctrinal matter. Put differently, source and residence as doctrinal rules can converge into a single concept in the modern global economy.If it is true that residence as a conceptual matter has become increasingly meaningless in the globalized world, tying the doctrinal rules of residence to the doctrinal rules for source can better effectuate the ultimate goals of the international tax regime. This Article introduces a proposal to define the residence of entities as domestic for purposes of US tax law based on the source of the income of such entities. In its most simplistic form - an entity would be a US Person if it earns over a threshold amount of US Source income. Of course, such an approach would prove more complex than such a simple statement, but the basic premise holds. The Article then demonstrates how such an approach could be used to resolve two of the most difficult and pressing issues confronting the modern US international tax regime: corporate inversions and offshore hedge funds.
Download or read book Self-employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Sources of Phosphorus in Stormwater and Street Dirt from Two Urban Residential Basins in Madison, Wisconsin, 1994-95 by : Robert J. Waschbusch
Download or read book Sources of Phosphorus in Stormwater and Street Dirt from Two Urban Residential Basins in Madison, Wisconsin, 1994-95 written by Robert J. Waschbusch and published by . This book was released on 1999 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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:
Book Synopsis CJEU Case Law in Direct Taxation: Territoriality and Fundamental Freedoms by : Stephanie Zolles
Download or read book CJEU Case Law in Direct Taxation: Territoriality and Fundamental Freedoms written by Stephanie Zolles and published by Linde Verlag GmbH. This book was released on 2023-07-13 with total page 253 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of territoriality and the fundamental freedoms The tension between the fundamental freedoms and the sovereignty of the Member States is omnipresent in the CJEU ́s case law on direct taxation. A significant number of cases concerned one of the core principles in national tax laws: the principle of territoriality. Although this principle is continuously mentioned in cases concerning the compatibility of direct tax measures with the fundamental freedoms, the case law seems to provoke more questions than answers. This book provides guidance on the meaning of territoriality in the CJEU ́s case law on direct taxation as well as on the role which this principle plays in the compatibility of domestic direct tax measures with the fundamental freedoms. During a critical and dogmatically oriented journey through the CJEU ́s case law, the reader can enjoy a comprehensive analysis, containing references to more than 300 cases. Without a doubt, this timeless reflection of the tension between the principle of territoriality and the fundamental freedoms is not only interesting from a dogmatic perspective, but also from a tax policy one.
Book Synopsis Global Perspectives on E-Commerce Taxation Law by : Subhajit Basu
Download or read book Global Perspectives on E-Commerce Taxation Law written by Subhajit Basu and published by Ashgate Publishing, Ltd.. This book was released on 2007 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field.
Book Synopsis Fundamentals of Risk Analysis and Risk Management by : Vlasta Molak
Download or read book Fundamentals of Risk Analysis and Risk Management written by Vlasta Molak and published by CRC Press. This book was released on 1996-11-26 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book bridges the gap between the many different disciplines used in applications of risk analysis to real world problems. Contributed by some of the world's leading experts, it creates a common information base and language for all risk analysis practitioners, risk managers, and decision makers. Valuable as both a reference for practitioners and a comprehensive textbook for students, Fundamentals of Risk Analysis and Risk Management is a unique contribution to the field. Its broad coverage ranges from basic theory of risk analysis to practical applications, risk perception, legal and political issues, and risk management.
Book Synopsis Conflict of Source Versus Residence-based Taxation in India with Reference to Fees for Technical Service by : M. Kumar Singh
Download or read book Conflict of Source Versus Residence-based Taxation in India with Reference to Fees for Technical Service written by M. Kumar Singh and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Highly internationalized trade and commerce, in wake of globalization, is a contemporary reality. However, the increasing porosity of national boundaries has not changed the fact that every country has the sovereign right to tax income accruing, arising or received in it, on account of activities carried on in its territory. Yet, an important change with internationalization is that increasingly there are more than one sovereign nation entitled to claim the 'right to tax'. This sovereign right to impose tax can be exercised by either the country from where the income is sourced (source country) or the country where the taxpayer resides (residence country). However, in current times, where it is common for individuals or businesses to have activities connected to two or more than two countries, exercise of this 'right to tax' by each nation has given rise to a complex situation of individuals or business entities being faced with the problem of being subjected to double taxation. The concept of 'residence jurisdiction' and 'source jurisdiction' are two fundamental concepts in the domain of international taxation. While conflict between these two concepts of taxation is a problem in the international arena, interestingly in India, this preference for one over the other has been a bone of contention between legislature and judiciary of the country. While judiciary has been showing preference for 'residence jurisdiction', the legislature has been in favour of a regime based on the concept of 'source jurisdiction'. This article explains the contours of this conflict as played out between the legislature and the judiciary in India. While endorsing the idea of tilt towards 'source jurisdiction' as a more appropriate regime for a developing country like India, this article argues that the need of the day is for a taxation regime which contains an adequate mixture of elements from both 'residence jurisdiction' and 'source jurisdiction'.
Book Synopsis The Code of Federal Regulations of the United States of America by :
Download or read book The Code of Federal Regulations of the United States of America written by and published by . This book was released on 1982 with total page 784 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government.
Book Synopsis Confidential Information Sources by : John M. Carroll
Download or read book Confidential Information Sources written by John M. Carroll and published by Elsevier. This book was released on 2014-06-28 with total page 409 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition includes the effects of massive computerization on the collection, storage, and reporting of personal data. For investigations and back-ground checks of any type, this outstanding volume tells how to hire reliable employees, sell to solvent customers, and purchase from reliable vendors. Carroll also examines troubling issues of ethics, accuracy, and privacy in our age of electronic information transfer. - Discusses the way the nation collects, stores, and uses personal information - Addresses the ethical questions about how personal data should be used - Highlights the changes in information collection brought about by computers
Book Synopsis Basic Laws and Authorities on Housing and Community Development, Revised Through January 3, 1977 by : United States
Download or read book Basic Laws and Authorities on Housing and Community Development, Revised Through January 3, 1977 written by United States and published by . This book was released on 1977 with total page 692 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Internal Revenue Cumulative Bulletin by : United States. Internal Revenue Service
Download or read book Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and published by . This book was released on 2000 with total page 628 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Volunteer Assistor's Guide written by and published by . This book was released on 1991 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
