The Law Relating To Income Tax
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Federal Taxes on Gratuitous Transfers
Author | : Joseph M. Dodge |
Publisher | : Aspen Publishing |
Total Pages | : 679 |
Release | : 2014-12-09 |
Genre | : Law |
ISBN | : 1454860421 |
This book deals with the federal income tax as it bears on gratuitous transfers and with the federal wealth transfer taxes. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. Features: Emphasis on text, statutes, and regulations, rather than cases (especially cases that involve routine application of law to facts) "Building block" organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students High-profile authorship in Joseph M. Dodge (a highly regarded tax specialist), Wendy C. Gerzog, and Bridget J. Crawford (both well-established in the field) The book reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. For example, special valuation rules are treated as basic, as opposed to being just "tacked on" as other books treat them. More emphasis on valuation and use of FLPs than in other books. Valuation is introduced early on and integrated with other material Integration of related income tax materials, including income taxation of estates and trusts Relation of tax doctrine to tax planning strategies Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle
Author | : Eva Escribano |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 254 |
Release | : 2019-05-10 |
Genre | : Law |
ISBN | : 940350644X |
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Your Federal Income Tax for Individuals
Author | : United States. Internal Revenue Service |
Publisher | : |
Total Pages | : 234 |
Release | : 1986 |
Genre | : Income tax |
ISBN | : |
Legal Interpretation of Tax Law
Author | : Robert F. van Brederode |
Publisher | : |
Total Pages | : 0 |
Release | : 2017 |
Genre | : Corporations |
ISBN | : 9789041184733 |
Legal Interpretation of Tax Law' is a comprehensive multi-jurisdiction survey of the interpretation of the corporate income tax and VAT and GST or other general sales tax laws. As a result of the globalization of trade and business, tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions. Effective consulting, whether internal or external, requires not only knowledge of tax law per se but also of how tax law is explained and interpreted by the courts of foreign jurisdictions. This book is the first to deal comparatively with tax law interpretation in economies engaged in cross-border investment at a global level.00The introduction outlines the theoretical approaches to legal interpretation in general and gives an overview of issues and topics relevant to taxation ? designed to help readers understand the jurisdictional chapters that follow. Each author pays detailed attention to such documentary elements as explanatory memoranda, administrative rulings, judicial precedents, judgments of foreign courts, legislative debates, and OECD guidelines.
State Taxation
Author | : Jerome R. Hellerstein |
Publisher | : |
Total Pages | : 0 |
Release | : 1998 |
Genre | : Taxation |
ISBN | : 9780791336496 |
Income Tax Law
Author | : Edward J. McCaffery |
Publisher | : Oxford University Press |
Total Pages | : 278 |
Release | : 2012 |
Genre | : Law |
ISBN | : 0195376714 |
This volume presents an introduction to the major topics in the field of federal income taxation, such as income, deductions, and recognition of gains and losses. After discussing central rules and doctrines individually, the author offers an explanation of the interplay among them, carefully describing how they work together to carry out the policy goals of the U.S. tax system.
Estimates of Federal Tax Expenditures
Author | : United States. Congress. Joint Committee on Internal Revenue Taxation |
Publisher | : |
Total Pages | : 20 |
Release | : 1976 |
Genre | : Revenue |
ISBN | : |
Tax Law Design and Drafting, Volume 1
Author | : Mr.Victor Thuronyi |
Publisher | : International Monetary Fund |
Total Pages | : 534 |
Release | : 1996-08-23 |
Genre | : Business & Economics |
ISBN | : 9781557755872 |
Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.