Author: Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 12
Book Description
Self-employment Tax
Author: International Income Taxation
Author: Robert J. PeroniPublisher: CCH
ISBN: 9780808018759
Category : Corporations, Foreign
Languages : en
Pages : 2356
Book Description
Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.
International Income Taxation: Code and Regulations--Selected Sections (2020-2021 Edition)
Author: Robert J PeroniPublisher:
ISBN: 9780808054702
Category :
Languages : en
Pages :
Book Description
Compiled by a team of distinguished law professors, the 2020-2021 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.
Corporate Income Taxes under Pressure
Author: Ruud A. de MooijPublisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Exploring the Nexus Doctrine In International Tax Law
Author: Ajit Kumar SinghPublisher: Kluwer Law International B.V.
ISBN: 9403533641
Category : Law
Languages : en
Pages : 234
Book Description
In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Introduction to United States International Taxation
Author: Paul R. McDanielPublisher:
ISBN: 9789041136565
Category : Aliens
Languages : en
Pages : 0
Book Description
This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. It sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad.
Income Taxation and International Mobility
Author: Jagdish N. BhagwatiPublisher: MIT Press
ISBN: 9780262022927
Category : Business & Economics
Languages : en
Pages : 256
Book Description
Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to "tax the brain drain."Today millions of people work in countries where they are not citizens. Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to tax the brain drain. The contributors, who include many of the leading theorists of international economics and public finance, look at how the difficult question of how horizontal equity is to be defined - between nationals at home and abroad or between nationals abroad and foreign citizens abroad - and tackle such questions as Should a country exercise income tax jurisdiction over its citizens abroad? If so, in what way? Is it practical to do so? The issues that these questions raise are complex, lying on the interface of politics, sociology, and economics. Income Taxation and International Mobility breaks significant new ground by analyzing these questions and building on the modern theory of optimal income taxation to examine the consequences of the possibility of outmigration on the appropriate exercise and design of income tax jurisdiction on those who live outside their native country. Theoretical analyses are presented in six chapters by the editors and by James Mirrlees, William Baumol, and Koichi Hamada. The well known tax law expert, Richard Pomp, examines the Philippines experience in taxing citizens abroad. The editors provide a substantial introduction that synthesizes the book's major analytical approaches and conclusions, and Richard Musgrave provides an insightful view of the issues in his Foreword.
Introduction to United States International Taxation
Author: James R. RepettiPublisher: Kluwer Law International B.V.
ISBN: 9403523905
Category : Law
Languages : en
Pages : 458
Book Description
The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
International Tax Policy and Double Tax Treaties
Author: Kevin HolmesPublisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
Book Description
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Global Perspectives on Income Taxation Law
Author: Reuven Shlomo Avi-YonahPublisher: Oxford University Press, USA
ISBN: 0195321367
Category : Law
Languages : en
Pages : 202
Book Description
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
