Author: Inhyuck Ha
Publisher:
ISBN:
Category :
Languages : en
Pages : 438
Book Description
The Minnesota Regional Integrated Modeling System
Author: Inhyuck Ha
Publisher:
ISBN:
Category :
Languages : en
Pages : 438
Book Description
Publisher:
ISBN:
Category :
Languages : en
Pages : 438
Book Description
Regional Recreation Participation Modeling
Author: William Anthony
Publisher:
ISBN:
Category : Outdoor recreation
Languages : en
Pages : 16
Book Description
Publisher:
ISBN:
Category : Outdoor recreation
Languages : en
Pages : 16
Book Description
Comprehensive Regional Modeling for Long-range Planning
Author: Robert A. Johnson
Publisher:
ISBN:
Category : Geographic information systems
Languages : en
Pages : 12
Book Description
Publisher:
ISBN:
Category : Geographic information systems
Languages : en
Pages : 12
Book Description
Managing the Human Service "system"
Author: DeWitt John
Publisher:
ISBN:
Category : Public welfare
Languages : en
Pages : 116
Book Description
Publisher:
ISBN:
Category : Public welfare
Languages : en
Pages : 116
Book Description
Overview of Integrated Modeling Framework
Author: Puget Sound Regional Council
Publisher:
ISBN:
Category : Regional planning
Languages : en
Pages : 12
Book Description
Publisher:
ISBN:
Category : Regional planning
Languages : en
Pages : 12
Book Description
Towards a Neutral Formulary Apportionment System in Regional Integration
Author: Shu-Chien Chen
Publisher: Kluwer Law International B.V.
ISBN: 9403532963
Category : Law
Languages : en
Pages : 471
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.
Publisher: Kluwer Law International B.V.
ISBN: 9403532963
Category : Law
Languages : en
Pages : 471
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.
Department Publications
Author: University of Minnesota. Dept. of Applied Economics
Publisher:
ISBN:
Category : Agriculture
Languages : en
Pages : 46
Book Description
Publisher:
ISBN:
Category : Agriculture
Languages : en
Pages : 46
Book Description
Users' Guide to the Minnesota Regional Development Simulation Laboratory
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 106
Book Description
Publisher:
ISBN:
Category :
Languages : en
Pages : 106
Book Description
A Regional Energy Information System for Minnesota
Author: Regional Energy Information System and Economic Impact Analysis Project
Publisher:
ISBN:
Category : Information storage and retrieval systems
Languages : en
Pages : 160
Book Description
Publisher:
ISBN:
Category : Information storage and retrieval systems
Languages : en
Pages : 160
Book Description
Socio-economic Profiles for Minnesota's Regional Systems
Author: University of Minnesota. Agricultural Extension Service
Publisher:
ISBN:
Category : Economic indicators
Languages : en
Pages : 134
Book Description
Publisher:
ISBN:
Category : Economic indicators
Languages : en
Pages : 134
Book Description