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Author: Brian J. Arnold Publisher: Kluwer Law International B.V. ISBN: 9403501723 Category : Law Languages : en Pages : 234
Book Description
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Author: Brian J. Arnold Publisher: Kluwer Law International B.V. ISBN: 9403501723 Category : Law Languages : en Pages : 234
Book Description
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Author: Brian Arnold Publisher: Springer ISBN: 9789041109590 Category : Business & Economics Languages : en Pages : 0
Book Description
As countries worldwide have become more economically integrated, The importance of international taxes has grown significantly, especially in countries formerly part of the Soviet Union or the Soviet bloc. The authors of this book worked with the OECD in conducting seminars on international tax for tax officials in these countries. In International Tax Primer, they address international aspects of income taxation in particular countries, emphasising tax treaties and other cooperative arrangements which help coordinate countries' income tax systems with the tax systems of their trading partners. International Tax Primer strikes a balance between the specific And The general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes: The role of the tax adviser, tax planning techniques, international double taxation, anti-avoidance rules, and an overview and analysis of tax treaties. The work also offers such practical features as : An extensive glossary of international tax terms; and a selected bibliography of international tax reference materials, including a list of periodicals devoted to international tax. Students, government officials, and tax practitioners who may be confronting international tax issues For The first time, As well as experienced international tax practitioners, will find International Tax Primer a helpful articulation of the fundamental principles that arise again and again in this field. it works as both an introduction and a refresher in an area where issues often prove more complex than they seem and where a return To The basics is often the most helpful means of untangling a multi-layered problem.
Author: Kevin Holmes Publisher: IBFD ISBN: 9087220235 Category : Double taxation Languages : en Pages : 433
Book Description
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: Ruud A. de Mooij Publisher: International Monetary Fund ISBN: 1513511777 Category : Business & Economics Languages : en Pages : 388
Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Author: Reuven S. Avi-Yonah Publisher: Edward Elgar Publishing ISBN: 1788978498 Category : Double taxation Languages : en Pages : 231
Book Description
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
Author: AICPA Publisher: Wiley ISBN: 9781119696865 Category : Business & Economics Languages : en Pages : 0
Book Description
The U.S. International Tax: Core Concepts (9.0 CPE Credits) covers topics such as distinguishing the differences between various types of global tax systems and certain characteristics of each, entity classifications and different forms of operating a business in a foreign country. Valuable to anyone who needs to understand the complexities of international taxation, this U.S. International Tax: Core Concepts bundle offers you the opportunity to build a solid foundation in U.S. international taxation. The two-part series of self-study online courses is part of the U.S. International Tax Certificate, a comprehensive learning program developed in partnership with Grant Thornton geared to help global finance and accounting professionals navigate the highly complex world of international taxation. The series includes: International Tax Foundation Introduction to U.S. Outbound and Inbound Transactions WHO WILL BENEFIT? Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation KEY TOPICS Tax Systems Inbound/Outbound Taxation Residency Foreign Tax Credits Entity Classification Subpart F Income Taxable presence in U.S. Income Sourcing in U.S. Withholding taxes in U.S. Tax Treaties Transfer pricing Key Actions under OECD BEPS initiative FDII GILTI LEARNING OBJECTIVES Part 1: Distinguish the differences between various types of global tax systems and certain characteristics of each Recall how the U.S. tax system works Recall entity classification and hybrids Recognize the different forms of operating a business in a foreign country Recall the concept of a permanent establishment / taxable presence in the United States and globally Recall U.S. income sourcing rules Identify general U.S. withholding tax rules Recognize the general function and benefits of most income tax treaties Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative Part 2: Identify business transactions that generate outbound tax issues. Recognize the approach for taxing U.S. persons with foreign activities. Describe the key tax reform provisions affecting outbound transactions. Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations. Recognize foreign currency issues affecting outbound transactions. Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships. Recall effectively connected income (ECI) to a U.S. trade or business Recall the rules for sourcing of income Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP) Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT) Indicate a general framework on the U.S. withholding taxes Digital Badge: Your Professional Distinction Set yourself apart as a future-ready financial professional. Upon completion, you will be awarded with a certificate in the form of a digital badge. Digital badges allow you to distinguish yourself in the marketplace and show your commitment to quality. The badge can be posted to your social media profiles and linked to your resume or email signature, providing maximum visibility to your achievement. Credit Info CPE CREDITS: Online: 9.0 (CPE credit info) NASBA FIELD OF STUDY: Taxes LEVEL: Basic PREREQUISITES: None ADVANCE PREPARATION: None DELIVERY METHOD: QAS Self-Study COURSE ACRONYM: ITC_181_1 Online Access Instructions A personal pin code is enclosed in the physical packaging that may be activated online upon receipt. Once activated, you will gain immediate online access to the product for one full year. System Requirements AICPA’s online CPE courses will operate in a variety of configurations, but only the configuration described below is supported by AICPA technicians. A stable and continuous internet connection is required. In order to record your completion of the online learning courses, please ensure you are connected to the internet at all times while taking the course. It is your responsibility to validate that CPE certificate(s) are available within your account after successfully completing the course and/or exam. Supported Operating Systems: Macintosh OS X 10.10 to present Windows 7 to present Supported Browsers: Apple Safari Google Chrome Microsoft Internet Explorer Mozilla Firefox Required Browser Plug-ins: Adobe Flash Adobe Acrobat Reader Technical Support: Please contact [email protected].
Author: Robert L. Williams Publisher: Kluwer Law International ISBN: 9789041149480 Category : Law Languages : en Pages : 0
Book Description
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.
Author: Andrew Lymer Publisher: Springer Science & Business Media ISBN: 9781402071577 Category : Business & Economics Languages : en Pages : 338
Book Description
International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Author: John Huston Publisher: Springer ISBN: Category : Business & Economics Languages : en Pages : 212
Book Description
This book is a comprehensive review of the tax treaty concept of a `permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the `fixed place of business' and `dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.
Author: Daniel N. Shaviro Publisher: Oxford University Press ISBN: 0199359768 Category : Law Languages : en Pages : 256
Book Description
International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
Author: Brian J. Arnold
Author: Brian J. Arnold
Author: Brian Arnold
Author: Kevin Holmes
Author: Ruud A. de Mooij
Author: Reuven S. Avi-Yonah
Author: AICPA
Author: Robert L. Williams
Author: Andrew Lymer
Author: John Huston
Author: Daniel N. Shaviro