Author: Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 12
Book Description
Self-employment Tax
Author: U.S. Tax Guide for Aliens
Author: United States Code
Author: United StatesU.S. International Taxation
Author: Joel D. KuntzLegislative History of United States Tax Conventions
Author: United States. Congress. Joint Committee on Internal Revenue TaxationPublisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1532
Book Description
Exploring the Nexus Doctrine In International Tax Law
Author: Ajit Kumar SinghPublisher: Kluwer Law International B.V.
ISBN: 9403533641
Category : Law
Languages : en
Pages : 234
Book Description
In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
International Tax Policy and Double Tax Treaties
Author: Kevin HolmesPublisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
Book Description
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
The Effects of Taxation on Multinational Corporations
Author: Martin FeldsteinPublisher: University of Chicago Press
ISBN: 0226241874
Category : Business & Economics
Languages : en
Pages : 338
Book Description
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
International Aspects of U.S. Income Taxation
Author: John P. Steines, Jr.Publisher:
ISBN: 9780692249635
Category :
Languages : en
Pages :
Book Description
Corporate Income Taxes under Pressure
Author: Ruud A. de MooijPublisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
Book Description
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.