International Income Taxation
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Corporate Income Taxes under Pressure
Author | : Ruud A. de Mooij |
Publisher | : International Monetary Fund |
Total Pages | : 388 |
Release | : 2021-02-26 |
Genre | : Business & Economics |
ISBN | : 1513511777 |
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.
International Aspects of U.S. Income Taxation
Author | : John P. Steines, Jr. |
Publisher | : |
Total Pages | : |
Release | : 2014 |
Genre | : |
ISBN | : 9780692249635 |
Global Perspectives on Income Taxation Law
Author | : Reuven Shlomo Avi-Yonah |
Publisher | : Oxford University Press, USA |
Total Pages | : 202 |
Release | : 2011 |
Genre | : Law |
ISBN | : 0195321367 |
In Global Perspectives on Income Taxation Law, Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class. It is arranged by subject matter in the order in which they are usually covered in U.S. tax law classes. The materials are drawn from a wide variety of countries, including developing countries.
International Applications of U.S. Income Tax Law
Author | : Ernest R. Larkins |
Publisher | : John Wiley & Sons |
Total Pages | : 456 |
Release | : 2003-11-20 |
Genre | : Business & Economics |
ISBN | : 0471482811 |
A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
International Company Taxation
Author | : Ulrich Schreiber |
Publisher | : Springer Science & Business Media |
Total Pages | : 179 |
Release | : 2013-01-30 |
Genre | : Business & Economics |
ISBN | : 3642363067 |
The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.
International Income Taxation: Code and Regulations--Selected Sections (2020-2021 Edition)
Author | : Robert J Peroni |
Publisher | : |
Total Pages | : |
Release | : 2020-06-30 |
Genre | : |
ISBN | : 9780808054702 |
Compiled by a team of distinguished law professors, the 2020-2021 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.
International Company Taxation and Tax Planning
Author | : Dieter Endres |
Publisher | : |
Total Pages | : 0 |
Release | : 2015 |
Genre | : Corporations |
ISBN | : 9789041145567 |
This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.
Federal Income Tax: Code and Regulations -- Selected Sections (2021-2022)
Author | : Robert J. Peroni |
Publisher | : |
Total Pages | : |
Release | : 2021-07-09 |
Genre | : |
ISBN | : 9780808056287 |
Now available as an eBook, The Federal Income Tax: Code and Regulations--Selected Sections provides a selection of the Internal Revenue Code and Treasury Regulations pertaining to income tax. This popular volume reflects the collective judgment of seven distinguished tax teachers and provides an effective mix of official materials for individual and business undergraduate and graduate tax courses offered in law and business schools. It provides in one volume, the provisions most commonly addressed in income tax courses. The book's highly readable 7-1/2 x 10 oversized page format make it easier to read for both professor and student. The book is an attractive alternative to the full text of the multi-volume Internal Revenue Code and Income Tax Regulations.
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.