International Applications of U.S. Income Tax Law PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download International Applications of U.S. Income Tax Law PDF full book. Access full book title International Applications of U.S. Income Tax Law by Ernest R. Larkins. Download full books in PDF and EPUB format.
Author: Ernest R. Larkins
Publisher: John Wiley & Sons
ISBN: 0471482811
Category : Business & Economics
Languages : en
Pages : 456
Get Book Here
Book Description
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!
Author: Ernest R. Larkins
Publisher: John Wiley & Sons
ISBN: 0471482811
Category : Business & Economics
Languages : en
Pages : 456
Get Book Here
Book Description
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!
Author: Ajit Kumar Singh
Publisher: Kluwer Law International B.V.
ISBN: 9403533641
Category : Law
Languages : en
Pages : 234
Get Book Here
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.
Author: Suzanne M. Luttman
Publisher: Emerald Group Publishing
ISBN: 1846639131
Category : Business & Economics
Languages : en
Pages : 182
Get Book Here
Book Description
Addresses various aspects of taxation, including tax policy issues at the federal, state, local, and international levels.
Author:
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 52
Get Book Here
Book Description
Author:
Publisher: CCH Canadian Limited
ISBN: 1553677919
Category :
Languages : en
Pages : 1166
Get Book Here
Book Description
Author: Niels Bammens
Publisher: IBFD
ISBN: 9087221592
Category : Conflict of laws
Languages : en
Pages : 1151
Get Book Here
Book Description
The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.
Author: United States
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 906
Get Book Here
Book Description
Author: Kevin Holmes
Publisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
Get Book Here
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.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 180
Get Book Here
Book Description
Author: Joel D. Kuntz
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages :
Get Book Here
Book Description
