Interpretation and Application of Tax Treaties in North America

Interpretation and Application of Tax Treaties in North America
Author: Juan Angel Becerra
Publisher: IBFD
Total Pages: 299
Release: 2007
Genre: Canada
ISBN: 9087220197

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.

Global Brazil and U.S.-Brazil Relations

Global Brazil and U.S.-Brazil Relations
Author: Samuel W. Bodman
Publisher: Council on Foreign Relations
Total Pages: 125
Release: 2011
Genre: Political Science
ISBN: 087609504X

July 12, 2011-Over the course of a generation, Brazil has emerged as both a driver of growth in South America and as an active force in world politics. A new Council on Foreign Relations (CFR)-sponsored Independent Task Force report asserts "that it is in the interest of the United States to understand Brazil as a complex international actor whose influence on the defining global issues of the day is only likely to increase."Brazil currently ranks as the world's fifth-largest landmass, fifth-largest population, and expects to soon be ranked the fifth largest economy. The report, Global Brazil and U.S.-Brazil Relations, recommends that "U.S. policymakers recognize Brazil's standing as a global actor, treat its emergence as an opportunity for the United States, and work with Brazil to develop complementary policies."The Task Force is chaired by former secretary of energy Samuel W. Bodman and former president of the World Bank James D. Wolfensohn, and directed by CFR Senior Fellow and Director for Latin America Studies, and Director of the Global Brazil Initiative Julia E. Sweig.Recognizing Brazil's global role, the report recommends that the Obama administration now fully endorse the country's bid for a seat as a permanent member of the United Nations Security Council (UNSC). It argues that "a formal endorsement from the United States for Brazil would go far to overcome lingering suspicion within the Brazilian government that the U.S. commitment to a mature relationship between equals is largely rhetorical."Domestically, Brazil's "inclusive growth has translated into a significant reduction of inequality, an expansion of the middle class, and a vibrant economy, all framed within a democratic context." Consequently, Brazil has been able to use its economic bona fides to leverage a stronger position in the international, commercial, and diplomatic arena.The report stresses the importance of regular communication between the presidents of both countries. "Cooperation between the United States and Brazil holds too much promise for miscommunication or inevitable disagreements to stand in the way of potential gains." A mature, working relationship means that "the United States and Brazil can help each other advance mutual interests even without wholesale policy agreements between the two," notes the report.The Task Force further recommends that- the U.S. Congress "include an elimination of the ethanol tariff in any bill regarding reform to the ethanol and biofuel tax credit regime."- the United States "take the first step to waive visa requirements for Brazilians by immediately reviewing Brazil's criteria for participation in the Visa Waiver Program."- the U.S. State Department create an Office for Brazilian Affairs and the National Security Council (NSC) centralize its efforts under a NSC director for Brazil in order to better coordinate the current decentralized U.S. policy.The bipartisan Task Force includes thirty distinguished experts on Brazil who represent a range of perspectives and backgrounds. The report includes a number of additional views by Task Force members, including one that notes, "We believe that a more gradual approach [regarding Brazil's inclusion as a full UNSC member] would likely have more success in navigating the diplomatic complexities presented by U.S. support for Brazil." Another view asserts, "If the United States supports, as the Obama administration has said it does, leadership structures in international institutions that are more reflective of international realities, it must support without qualifications Brazil's candidacy [for the UNSC]."

Global Trends 2040

Global Trends 2040
Author: National Intelligence Council
Publisher: Cosimo Reports
Total Pages: 158
Release: 2021-03
Genre:
ISBN: 9781646794973

"The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.

International Business Taxation

International Business Taxation
Author: Sol Picciotto
Publisher: Praeger
Total Pages: 424
Release: 1992-03-02
Genre: Business & Economics
ISBN:

This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

Brazil: Tax Expenditure Rationalization Within Broader Tax Reform

Brazil: Tax Expenditure Rationalization Within Broader Tax Reform
Author: Maria Delgado Coelho
Publisher: International Monetary Fund
Total Pages: 46
Release: 2021-09-24
Genre: Business & Economics
ISBN: 1513596624

The excessive complexity and burden of the Brazilian tax system, riddled by cumulative indirect taxes and heavy payroll contributions, have led to an accumulation of fiscal incentives aimed at reducing its burden on taxpayers and productive activities. Federal and subnational tax expenditures currently stand at over 5 percent of GDP. Rationalizing them can only be comprehensively feasible in the context of a broader sequenced tax reform, and could reduce resource misallocation and income inequality, as well as provide new revenues.

Fiscal Regimes for Extractive Industries—Design and Implementation

Fiscal Regimes for Extractive Industries—Design and Implementation
Author: International Monetary Fund. Fiscal Affairs Dept.
Publisher: International Monetary Fund
Total Pages: 82
Release: 2012-08-16
Genre: Business & Economics
ISBN: 1498340067

Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Doing Business 2020

Doing Business 2020
Author: World Bank
Publisher: World Bank Publications
Total Pages: 241
Release: 2019-11-21
Genre: Business & Economics
ISBN: 1464814414

Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.

Introduction to the Law of Double Taxation Conventions

Introduction to the Law of Double Taxation Conventions
Author: Michael Lang
Publisher: Linde Verlag GmbH
Total Pages: 266
Release: 2021-04-01
Genre: Law
ISBN: 3709408628

The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.