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Elements of International Income Taxation

Elements of International Income Taxation PDF Author: Philippe Malherbe
Publisher: Bruylant
ISBN: 2802750542
Category : Law
Languages : en
Pages : 194

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Book Description
Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.

Elements of International Income Taxation

Elements of International Income Taxation PDF Author: Philippe Malherbe
Publisher: Bruylant
ISBN: 2802750542
Category : Law
Languages : en
Pages : 194

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Book Description
Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.

International Taxation

International Taxation PDF Author: Joseph Isenbergh
Publisher: Thomson West
ISBN:
Category : Business & Economics
Languages : en
Pages : 297

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Book Description
International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index

International Taxation: U.S. Taxation of Foreign Persons and Foreign Income (2022)

International Taxation: U.S. Taxation of Foreign Persons and Foreign Income (2022) PDF Author: Joseph Isenbergh
Publisher:
ISBN: 9780808056744
Category :
Languages : en
Pages :

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Book Description
International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners.

International Law of Taxation

International Law of Taxation PDF Author: Peter Hongler
Publisher: Oxford University Press
ISBN: 019289871X
Category :
Languages : en
Pages : 288

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Book Description
This addition to the Elements of International Law series explores the dynamic discipline of international tax law, with a particular focus on how the international tax regime is embedded within the broader context of international law.

International Income Taxation: Code and Regulations--Sel Sect 2022-2023 Ed

International Income Taxation: Code and Regulations--Sel Sect 2022-2023 Ed PDF Author: Robert Peroni
Publisher:
ISBN: 9780808057338
Category :
Languages : en
Pages : 3072

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Book Description
Having the right resources on hand is invaluable for any subject and occupation. This is especially true for professionals of international taxation. Wolters Kluwer's International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) is a convenient, easy-to-read reference for international income tax legislation, regulations, and more. Features of International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) is a comprehensive desk guide to the U.S. taxation of both foreign and domestic entities with income sources outside the country. The reference includes selected provisions of the Internal Revenue Code and Income Tax Regulations. All selections have been deemed relevant to the topic and essential for international tax teachers, students, and practitioners, including CPAs, professional tax preparers, corporate controllers, and others. Instructors and students alike find this reference to be the ideal companion to international tax coursebooks, making it a valuable addition to undergraduate or graduate classrooms in law and business. The book is also recommended for current practitioners as a handy desk reference. The information presented is thorough, and skimmable formatting makes it easy to quickly find the resources needed to complete a preparation or filing. With constant changes to tax processes and filing from the IRS, an up-to-date resource becomes invaluable. International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) reflects all recent developments, legislation, and regulations as of June 1, 2020. This allows practitioners, instructors, and students to reference the most current information, ensuring their resulting work is current and up to date. Benefits of Use International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) was compiled and edited by a team of distinguished law professors, drawing upon years of experience in legal practice and education. The team includes: Robert J. Peroni, Coordinating Editor: Parker C. Fielder Regents Professor of Law, University of Texas Richard C. Pugh, Contributing Editor: Distinguished Professor of Law, University of San Diego Charles H. Gustafson, Contributing Editor: Professor of Law, Georgetown University The book was composed with portability and approachability in mind. Unlike a full multi-volume work, it is a single volume that travels well between home and office, classroom and dorm, and anywhere else the reader may need a reference. Its printing style is reader-friendly as well, with a large 71/4" by 10" format and enlarged type fonts. This contributes to an enhanced readability, allowing for quick scanning and long study sessions. Order International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) When teaching, studying, or practicing international tax preparation, it helps to have a convenient reference. From Wolters Kluwer, International Income Taxation: Code & Regulations, Selected Sections (2020-2021 Edition) is a portable and approachable compilation of selected legislation and regulations for international income tax. Order in softcover or eBook format today.

International Tax Primer

International Tax Primer PDF Author: Brian J. Arnold
Publisher:
ISBN: 9789041109590
Category : Aliens
Languages : en
Pages : 149

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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.

International Taxation

International Taxation PDF Author: Joseph Isenbergh
Publisher:
ISBN: 9780808043447
Category :
Languages : en
Pages :

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Book Description
International Taxation is a comprehensive four volume treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to:-Structure international corporate transactions for maximum benefit.-Minimize liability under applicable laws and treaties.-Practice effectively and compliantly within the complex web of legal authority.The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts:Part I Elements of International Taxation Part II U.S. Taxation of Nonresident Aliens and Foreign CorporationsPart III U.S. Taxation of Foreign IncomePart IV Foreign Currency QuestionsPart V International Corporate ReorganizationsPart VI Income Tax TreatiesPart VII Withholding in International Taxation Part VIII International Transfer Taxation Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.

The principle of non-discrimination in international and European tax law

The principle of non-discrimination in international and European tax law PDF Author: Niels Bammens
Publisher: IBFD
ISBN: 9087221592
Category : Conflict of laws
Languages : en
Pages : 1130

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Book Description
"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. First, the partial overlap of the two non-discrimination rules may cause frictions. Complex triangular situations are possible, with conflicting rules giving rise to interpretation problems. A second issue discussed in this context is whether national courts of EU Member States are influenced by ECJ case law on the fundamental freedoms when interpreting the non-discrimination provision in tax treaties. Given the deficiencies of that provision, courts may be tempted to draw inspiration from the European standard. The relevant case law is discussed in order to determine whether there is indeed such an influence, and whether such an influence is appropriate."--Extracted from publisher website on May 20, 2015.

International Income Taxation

International Income Taxation PDF Author: Robert J. Peroni
Publisher: CCH
ISBN: 9780808018759
Category : Business & Economics
Languages : en
Pages : 3059

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Book Description
Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability.

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option PDF Author: Richard Krever
Publisher: Kluwer Law International B.V.
ISBN: 9403506156
Category : Law
Languages : en
Pages : 368

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Book Description
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules.