[PDF] Essays In International Corporate Taxation eBook

Author : United States. Department of the Treasury
Publisher :
Page : 332 pages
File Size : 40,96 MB
Release : 1977
Category : Corporations, Foreign
ISBN :

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The essays analyse the interactions between tax law and tax policy. The analyses evaluate changes which presuppose the foreign tax credit mechanism, the separate taxation of corporations and their shareholders, and other basic elements in US taxation of foreign income.

Author : Dhruv Sanghavi
Publisher : Bloomsbury Publishing
Page : 232 pages
File Size : 39,91 MB
Release : 2020-05-06
Category : Business & Economics
ISBN : 9390077745

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Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom

Author : Klaus Vogel
Publisher : Kluwer Law International B.V.
Page : 284 pages
File Size : 12,62 MB
Release : 2002-09-03
Category : Business & Economics
ISBN : 9041198415

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Compilation of the 16 English language contributions of "Staaten und Steuern (States and Taxes)", the original festschrift to honour Klaus Vogel.

Author : Yariv Brauner
Publisher : Kluwer Law International B.V.
Page : 355 pages
File Size : 34,92 MB
Release : 2012-03-01
Category : Law
ISBN : 9041141987

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Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world’s most respected international tax experts—including the late Paul McDaniel, in whose honor these essays were assembled—this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of “horizontal equity”; the international tax norm of “income source”; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.

Author : Michael J. Graetz
Publisher : Yale Law Library
Page : 536 pages
File Size : 29,52 MB
Release : 2016-05-02
Category : Double taxation
ISBN : 9780692630143

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Publicity about tax avoidance techniques of multinational corporations and wealthy individuals has moved discussion of international income taxation from the backrooms of law and accounting firms to the front pages of news organizations around the world. In the words of a top Australian tax official, international tax law has now become a topic of barbeque conversations. Public anger has, in turn, brought previously arcane issues of international taxation onto the agenda of heads of government around the world. Despite all the attention, however, issues of international income taxation are often not well understood. In this collection of essays, written over the past two decades, renowned tax expert Michael J. Graetz reveals how current international tax policy came into place nearly a century ago, critiques the inadequate principles still being used to make international tax policy, identifies and dissects the most prevalent tax avoidance techniques, and offers important suggestions for reform. This book is indispensable for anyone interested in international income taxation.