Dividends Under the Income Tax
Author | : Daniel Mark Holland |
Publisher | : |
Total Pages | : 218 |
Release | : 1962 |
Genre | : Business & Economics |
ISBN | : |
Download Dividends Under The Income Tax full books in PDF, epub, and Kindle. Read online free Dividends Under The Income Tax ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
Author | : Daniel Mark Holland |
Publisher | : |
Total Pages | : 218 |
Release | : 1962 |
Genre | : Business & Economics |
ISBN | : |
Author | : Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation |
Publisher | : |
Total Pages | : 16 |
Release | : 1953 |
Genre | : Dividends |
ISBN | : |
Author | : Guglielmo Maisto |
Publisher | : IBFD |
Total Pages | : 1093 |
Release | : 2012 |
Genre | : Corporations |
ISBN | : 9087221398 |
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Author | : D. Larry Crumbley |
Publisher | : Prentice Hall |
Total Pages | : 300 |
Release | : 1981 |
Genre | : Law |
ISBN | : |
Author | : Marjaana Helminen |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 306 |
Release | : 2010-01-01 |
Genre | : Law |
ISBN | : 9041132066 |
The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: and Payments made under dividend-stripping arrangements. and Fictitious profit distributions. and Economic benefits in the context of transfer pricing. and Returns on debt-equity hybrids. and Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law. The approaches adopted in different statesand national tax law are covered by a more general analysis. The comprehensive coverage and practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Author | : American Institute of Certified Public Accountants |
Publisher | : |
Total Pages | : 60 |
Release | : 1976 |
Genre | : Corporations |
ISBN | : |
Author | : United States. Congress. House. Committee on Financial Services. Subcommittee on Oversight and Investigations |
Publisher | : |
Total Pages | : 248 |
Release | : 2003 |
Genre | : Business & Economics |
ISBN | : |