The Lancaster Law Review

The Lancaster Law Review PDF Author:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 450

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The Lancaster Law Review

The Lancaster Law Review PDF Author:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 450

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The Lancaster Law Review

The Lancaster Law Review PDF Author:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 454

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The Lancaster Law Review

The Lancaster Law Review PDF Author: Henry Clay Brubaker
Publisher:
ISBN:
Category : Law
Languages : en
Pages :

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The Law Magazine and Law Review

The Law Magazine and Law Review PDF Author:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 398

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The Law Magazine and Law Review

The Law Magazine and Law Review PDF Author: Wlliam S. Hein Company
Publisher: BoD – Books on Demand
ISBN: 3752574747
Category : Fiction
Languages : en
Pages : 398

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Book Description
Reprint of the original, first published in 1867.

Report of the First[-thirty-first] Annual Meeting of the Virginia State Bar Association

Report of the First[-thirty-first] Annual Meeting of the Virginia State Bar Association PDF Author: Virginia State Bar Association
Publisher:
ISBN:
Category : Bar associations
Languages : en
Pages : 380

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The Law Magazine and Law Review, Or, Quarterly Journal of Jurisprudence

The Law Magazine and Law Review, Or, Quarterly Journal of Jurisprudence PDF Author:
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 760

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Harvard Law Review

Harvard Law Review PDF Author:
Publisher:
ISBN:
Category : Electronic journals
Languages : en
Pages : 664

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Towards a Neutral Formulary Apportionment System in Regional Integration

Towards a Neutral Formulary Apportionment System in Regional Integration PDF Author: Shu-Chien Chen
Publisher: Kluwer Law International B.V.
ISBN: 9403532963
Category : Law
Languages : en
Pages : 471

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Book Description
International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.

Report of the ... Annual Meeting of the Virginia State Bar Association

Report of the ... Annual Meeting of the Virginia State Bar Association PDF Author: Virginia State Bar Association. Meeting
Publisher:
ISBN:
Category : Bar associations
Languages : en
Pages : 340

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