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Author: N.T. Angkatavanich Publisher: ISBN: Category : Languages : en Pages :
Book Description
This is the first in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This first part begins by providing a broad overview of the international tax paradigm, opening with the transfer tax regime, moving on to the individual income tax regime and, finally, addressing the taxation of trusts in cross-border transactions.
Author: N.T. Angkatavanich Publisher: ISBN: Category : Languages : en Pages :
Book Description
This is the first in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This first part begins by providing a broad overview of the international tax paradigm, opening with the transfer tax regime, moving on to the individual income tax regime and, finally, addressing the taxation of trusts in cross-border transactions.
Author: N.T. Angkatavanich Publisher: ISBN: Category : Languages : en Pages :
Book Description
This is the second in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This second part provides an overview of various specialized tax regimes that apply to cross-border transactions. These regimes - the special taxes imposed on U.S. expatriates, the corporate anti-deferral regimes for controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs) and the withholding tax regime applicable to foreign investment in U.S. real estate - are intended to address certain historical transactions and structures perceived as abusive or potentially abusive.
Author: Brian J. Arnold Publisher: Kluwer Law International B.V. ISBN: 9403501723 Category : Law Languages : en Pages : 234
Book Description
Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book 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 following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.
Author: International Monetary Fund. Fiscal Affairs Dept. Publisher: International Monetary Fund ISBN: 1498345204 Category : Business & Economics Languages : en Pages : 78
Book Description
Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
Author: Robert L. Williams Publisher: Kluwer Law International ISBN: 9789041149480 Category : Law Languages : en Pages : 0
Book Description
This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.
Author: Reuven S. Avi-Yonah Publisher: Cambridge University Press ISBN: 9780521852838 Category : Law Languages : en Pages : 224
Book Description
This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
Author: Publisher: Bloomsbury Publishing ISBN: 1780436777 Category : Law Languages : en Pages : 829
Book Description
This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277
Author: Board of Governors of the Federal Reserve System Publisher: ISBN: 9780894991967 Category : Banks and Banking Languages : en Pages : 0
Book Description
Provides an in-depth overview of the Federal Reserve System, including information about monetary policy and the economy, the Federal Reserve in the international sphere, supervision and regulation, consumer and community affairs and services offered by Reserve Banks. Contains several appendixes, including a brief explanation of Federal Reserve regulations, a glossary of terms, and a list of additional publications.
Author: N.T. Angkatavanich
Author: N.T. Angkatavanich
Author: N.T. Angkatavanich
Author: Brian J. Arnold
Author: International Monetary Fund. Fiscal Affairs Dept.
Author: Robert L. Williams
Author: United States. Internal Revenue Service
Author: Reuven S. Avi-Yonah
Author: 
Author: Ernest Bancroft Conant
Author: Board of Governors of the Federal Reserve System