Tax Rules Affecting Foreign Conventions

Tax Rules Affecting Foreign Conventions PDF Author: United States. Congress. Senate. Committee on Finance. Subcommittee on Tourism and Sugar
Publisher:
ISBN:
Category : Congresses and conventions
Languages : en
Pages : 240

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Tax Rules Affecting Foreign Conventions

Tax Rules Affecting Foreign Conventions PDF Author: United States. Congress. Senate. Committee on Finance. Subcommittee on Tourism and Sugar
Publisher:
ISBN:
Category : Congresses and conventions
Languages : en
Pages : 240

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U.S. Tax Treaties

U.S. Tax Treaties PDF Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 28

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"Taxes Covered"

Author: Patricia Brandstetter
Publisher: IBFD
ISBN: 9087220898
Category : Capital levy
Languages : en
Pages : 281

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Book Description
"The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.

Double Taxation Conventions

Double Taxation Conventions PDF Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 40

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Tax Rules Affecting Foreign Conventions

Tax Rules Affecting Foreign Conventions PDF Author: United States. Congress. Senate. Committee on Finance. Subcommittee on Tourism and Sugar
Publisher:
ISBN:
Category : Congresses and conventions
Languages : en
Pages : 0

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Interpretation and Application of Tax Treaties in North America

Interpretation and Application of Tax Treaties in North America PDF Author: Juan Angel Becerra
Publisher: IBFD
ISBN: 9087220197
Category : Canada
Languages : en
Pages : 299

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Book Description
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Double Taxation Conventions

Double Taxation Conventions PDF Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 66

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Tax Rules in Non-tax Agreements

Tax Rules in Non-tax Agreements PDF Author: Michael Lang
Publisher: IBFD
ISBN: 9087221479
Category : Law
Languages : en
Pages : 961

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Book Description
Tax rules in non-tax agreements is a topic of great relevance in practice. Yet, up to now, this area of tax law has been generally neglected by researchers. The aim of this book is to close this gap in tax law research and to analyse the provisions of international agreements and similar legal instruments under international law which provide for a special domestic law tax treatment for specific individuals and international organizations. Twenty-four national reports from countries across the globe have been compiled and are published in this volume. Seventy experts, including the authors of the national reports, convened for a joint conference on "Tax Rules in Non-Tax Agreements" in Rust (Austria) from 7-9 July 2011. The national reports focus on the interaction of tax rules in non-tax agreements with the corresponding tax treaty rules. Moreover, possible matters of dispute regarding the justification of these tax rules within the legal and political frameworks of the different states are given much attention. The objective of this book is to show the relevance of tax rules in non-tax agreements, to highlight problematic issues and to encourage future research in this important field of tax law

The Impact of Community Law on Tax Treaties:Issues and Solutions

The Impact of Community Law on Tax Treaties:Issues and Solutions PDF Author: Pasquale Pistone
Publisher: Kluwer Law International B.V.
ISBN: 9041198601
Category : Business & Economics
Languages : en
Pages : 424

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Book Description
Study on the question of harmonization of direct taxation among European Community Member States: how Member States must comply with EC Law as they apply their tax treaties, how EC law regulates cross-border tax issues within the Community, and how EC law affects tax treaties between EU Member States and third countries. The book provides expert commentary on 27 leading tax cases from the European Court of Justice, and gives the proposal of EC Model Tax Convention, which combines existing provisions of international tax law with the principles of Community tax law.

International Tax Treaties

International Tax Treaties PDF Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 128

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Book Description