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Author: United States Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977839497
Category :
Languages : en
Pages : 304
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Book Description
Offshore profit shifting and the U.S. Tax Code. Part 2 (Apple Inc.) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Thirteenth Congress, first session, May 21, 2013.
Author: United States Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977839497
Category :
Languages : en
Pages : 304
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Book Description
Offshore profit shifting and the U.S. Tax Code. Part 2 (Apple Inc.) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Thirteenth Congress, first session, May 21, 2013.
Author: Reny Toupin
Publisher: Nova Science Publishers
ISBN: 9781628084795
Category : Corporations, American
Languages : en
Pages : 0
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Book Description
On 21 May 2013, the Permanent Subcommittee on Investigations (PSI) of the U.S. Senate Homeland Security and Government Affairs Committee held a hearing that was a continuation of a series of reviews conducted by the Subcommittee on how individual and corporate taxpayers are shifting billions of dollars offshore to avoid U.S. taxes. This book examines those hearings and how Apple Inc., a U.S. multinational corporation, has used a variety of offshore structures, arrangements, and transactions to shift billions of dollars in profits away from the United States and into Ireland, where Apple has negotiated a special corporate tax rate of less than two percent. This book examines how Apple Inc. transferred the economic rights to its intellectual property through a cost sharing agreement with its own offshore affiliates, and was thereby able to shift tens of billions of dollars offshore to a low tax jurisdiction and avoid U.S. tax. Apple Inc then utilised U.S. tax loopholes, including the so-called "check-the-box" rules, to avoid U.S. taxes on $44 billion in taxable offshore income over the past four years, or about $10 billion in tax avoidance per year. The book also examines some of the weaknesses and loopholes in certain U.S. tax code provisions, including transfer pricing, Subpart F, and related regulations, that enable multinational corporations to avoid U.S. taxes.
Author: United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
Publisher:
ISBN:
Category :
Languages : en
Pages : 40
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Book Description
Author: United States. Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781981769520
Category :
Languages : en
Pages : 644
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Book Description
Offshore profit shifting and the U.S. Tax Code. Part 1 (Microsoft and Hewlett-Packard) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Twelfth Congress, second session, September 20, 2012.
Author: United States. Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977844361
Category :
Languages : en
Pages : 644
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Book Description
Offshore profit shifting and the U.S. Tax Code. Part 1 (Microsoft and Hewlett-Packard) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Twelfth Congress, second session, September 20, 2012.
Author: Eva Escribano
Publisher: Kluwer Law International B.V.
ISBN: 940350644X
Category : Law
Languages : en
Pages : 249
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Book Description
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.
Author: United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
Publisher:
ISBN:
Category : Corporations, American
Languages : en
Pages : 1284
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Book Description
Author: Larry N. Gerston
Publisher: Taylor & Francis
ISBN: 1040083250
Category : Political Science
Languages : en
Pages : 294
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Book Description
Whereas our nation was once united in purpose, today it is bitterly divided. Why? Racial discrimination, diminishing educational opportunities, poor economic mobility, greedy corporations, and an unresponsive federal government have combined to create two Americas. Presented in Gerston‘s characteristic, no-holds-barred style of wit and candor, Revi
Author: Sergio André Rocha
Publisher: Kluwer Law International B.V.
ISBN: 9041167080
Category : Law
Languages : en
Pages : 338
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Book Description
The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Author: L. Brennan
Publisher: Springer
ISBN: 1137361948
Category : Business & Economics
Languages : en
Pages : 342
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Book Description
Enacting Globalization consists of a rich set of papers with a variety of disciplinary perspectives, focusing on Globalization and its portrayal through International Integration as manifested by its myriad flows such as people, trade, capital and knowledge flows.
