Federal Income Taxation of Intellectual Properties and Intangible Assets

Federal Income Taxation of Intellectual Properties and Intangible Assets PDF Author: Philip F. Postlewaite
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 2542

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Book Description

Federal Income Taxation of Intellectual Properties and Intangible Assets

Federal Income Taxation of Intellectual Properties and Intangible Assets PDF Author: Philip F. Postlewaite
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 2542

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Book Description


International Taxation of Banking

International Taxation of Banking PDF Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 9403510951
Category : Law
Languages : en
Pages : 468

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Book Description
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Self-employment Tax

Self-employment Tax PDF Author:
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 12

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Book Description


OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264921915
Category :
Languages : en
Pages : 658

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Book Description
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Tax Treatment of Intangible Assets

Tax Treatment of Intangible Assets PDF Author: United States. Congress. House. Committee on Ways and Means
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 444

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Basis of Assets

Basis of Assets PDF Author:
Publisher:
ISBN:
Category : Capital gains tax
Languages : en
Pages : 20

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Book Description


Accounting and Valuation Guide: Assets Acquired to Be Used in Research and Development Activities

Accounting and Valuation Guide: Assets Acquired to Be Used in Research and Development Activities PDF Author: AICPA
Publisher: John Wiley & Sons
ISBN: 1937352781
Category : Business & Economics
Languages : en
Pages : 208

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Book Description
This new guide provides guidance and illustrations regarding the initial and subsequent accounting for, valuation of, and disclosures related to acquired intangible assets used in research and development activities (IPR&D assets). This is a valuable resource for preparers of financial statements, auditors, accountants and valuation specialists seeking an advanced understanding of the accounting, valuation, and disclosures related to acquired IPR&D assets.

U.S. Taxation of International Mergers, Acquisitions, and Joint Ventures

U.S. Taxation of International Mergers, Acquisitions, and Joint Ventures PDF Author: D. Kevin Dolan
Publisher:
ISBN:
Category : Consolidation and merger of corporations
Languages : en
Pages :

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Book Description


Transfer Pricing and the Arm's Length Principle in International Tax Law

Transfer Pricing and the Arm's Length Principle in International Tax Law PDF Author: Jens Wittendorff
Publisher: Kluwer Law International B.V.
ISBN: 9041132708
Category : Law
Languages : en
Pages : 914

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Book Description
The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

Accounting for Goodwill and Other Intangible Assets

Accounting for Goodwill and Other Intangible Assets PDF Author: Ervin L. Black
Publisher: John Wiley & Sons
ISBN: 1119157153
Category : Business & Economics
Languages : en
Pages : 290

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Book Description
Concepts, methods, and issues in calculating the fair value of intangibles Accounting for Goodwill and Other Intangible Assets is a guide to one of the most challenging aspects of business valuation. Not only must executives and valuation professionals understand the complicated set of rules and practices that pertain to intangibles, they must also be able to recognize when to apply them. Inside, readers will find these many complexities clarified. Additionally, this book assists professionals in overcoming the difficulties of intangible asset accounting, such as the lack of market quotes and the conflicts among various valuation methodologies. Even the rarest and most problematic situations are treated in detail in Accounting for Goodwill and Other Intangible Assets. For example, the authors analyze principles for identifying finite intangible assets and appropriately accounting for amortization expenses or impairment losses. Using the information in this book, the results of these calculations can also be reported with precision on financial statements. These topics are especially important for ensuring the success of any asset acquisition or business combination. In these special cases, the utmost accuracy is essential. This book provides: Rules for identifying and recognizing intangible assets in business combinations and asset acquisitions Guidance on the accurate valuation and carrying amount calculation of acquired and self-created intangibles Tips for overcoming the challenges unique to intangible assets, including impairment testing Clear instructions for disclosing intangible assets, goodwill, and amortization expenses Accounting for Goodwill and Other Intangible Assets is an indispensable reference for valuation students and specialists. Ervin L. Black and Mark L. Zyla provide thorough instructions for understanding, accounting for, and reporting this challenging asset class.