Federal-state Reference Guide PDF Download
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Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Civil service
Languages : en
Pages : 208
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Book Description
Author: Cornelia Butler Flora
Publisher: Routledge
ISBN: 0429974329
Category : Social Science
Languages : en
Pages : 433
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Book Description
Communities in rural America are a complex mixture of peoples and cultures, ranging from miners who have been laid off in West Virginia, to Laotian immigrants relocating in Kansas to work at a beef processing plant, to entrepreneurs drawing up plans for a world-class ski resort in California's Sierra Nevada. Rural Communities: Legacy and Change uses its unique Community Capitals framework to examine how America's diverse rural communities use their various capitals (natural, cultural, human, social, political, financial, and built) to address the modern challenges that face them. Each chapter opens with a case study of a community facing a particular challenge, and is followed by a comprehensive discussion of sociological concepts to be applied to understanding the case. This narrative, topical approach makes the book accessible and engaging for undergraduate students, while its integrative approach provides them with a framework for understanding rural society based on the concepts and explanations of social science. This fifth edition is updated throughout with 2013 census data and features new and expanded coverage of health and health care, food systems and alternatives, the effects of neoliberalism and globalization on rural communities, as well as an expanded resource and activity section at the end of each chapter.
Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
ISBN: 9403535520
Category : Law
Languages : en
Pages : 252
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Book Description
Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Civil service
Languages : en
Pages : 208
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Book Description
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709411009
Category : Law
Languages : en
Pages : 412
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Book Description
A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Author: Erik Pinetz
Publisher: Linde Verlag GmbH
ISBN: 3709408822
Category : Law
Languages : en
Pages : 454
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Book Description
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 12
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Book Description
Author: Andreas Waltrich
Publisher: Kluwer Law International B.V.
ISBN: 9041168389
Category : Law
Languages : en
Pages : 340
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Book Description
The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.
Author: CQ Researcher,
Publisher: CQ Press
ISBN: 1506361056
Category : Political Science
Languages : en
Pages : 329
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Book Description
What are the driving forces behind Smart Cities? What are the ramifications of increasing the minimum wage? What are the causes of aging infrastructure and how should they be addressed? These are just some of the provocative questions that are considered in the new edition of Urban Issues. For current coverage of urban politics, readers will appreciate the balanced and unbiased reporting of CQ Researcher. Urban Issues provides a window into how policy is created and implemented in America’s cities and is sure to spark classroom discussions. Each chapter examines the key players, stakes, background, and lessons for the future, while covering the range of facts, analyses, and opinions surrounding each issue.
![The American Middle Class [2 volumes] PDF](https://books.google.com/books/content/images/frontcover/IEXPEAAAQBAJ?fife=w80-h100)
Author: Robert S. Rycroft
Publisher: Bloomsbury Publishing USA
ISBN:
Category : History
Languages : en
Pages : 738
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Book Description
What is the "American Dream"? This book's author argues that contrary to what many believe, it is not achieving the wealth necessary to enter the top one percent but rather becoming members of the great middle class by dint of hard work and self-discipline. Americans of all classes consider themselves to be "middle class." There are Americans who by any objective standard should be considered poor who would insist they are middle class, just as other Americans who should be considered wealthy also insist they are middle class. Thinking of yourself and being thought of by others as middle class is the "American Dream" for tens of millions of people. But an enduring problem of the American middle class is the worry that the "Dream" is coming apart—that forces are lurking in the shadows waiting to steal their progress and throw them back into "poverty." This thought-provoking reference explores a disparate multitude of issues associated with being middle class in America. It addresses a range of questions and subtopics, including the meaning of the term "middle class"; how middle class status is expressed by both the majority and the various minorities that make up the American mosaic; what economic pressures are bearing down on the middle class; and how economists and others attempt to make sense of the economic issues of the day. Readers will also better understand how political institutions and public policies are shaping the way the middle class views the world; how labor, housing, education, and crime-related issues have influenced the development and growth of the middle class; the norms of the middle class versus those of other classes in society; and the role of culture and media in shaping how members of the middle class view themselves—and how they are viewed by others. This two-volume set provides a comprehensive look at the American middle class that supports student research in economics, social studies, cultural studies, and political history. The content supports teachers in their development of lesson plans and assignments that directly align with the Common Core State Standards and the recommendations of the National Curriculum Standards for Social Studies (NCSS) with respect to all ten NCSS themes.
Author: Philip Daniel
Publisher: Taylor & Francis
ISBN: 1317330145
Category : Business & Economics
Languages : en
Pages : 381
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Book Description
The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics.
