[PDF] Foreign Affairs A Primer On International Tax And Estate Planning Part 2 eBook
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This is the second in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This second part provides an overview of various specialized tax regimes that apply to cross-border transactions. These regimes - the special taxes imposed on U.S. expatriates, the corporate anti-deferral regimes for controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs) and the withholding tax regime applicable to foreign investment in U.S. real estate - are intended to address certain historical transactions and structures perceived as abusive or potentially abusive.
This is the first in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This first part begins by providing a broad overview of the international tax paradigm, opening with the transfer tax regime, moving on to the individual income tax regime and, finally, addressing the taxation of trusts in cross-border transactions.
This authoritative and completely updated new edition takes you step-by-step through all the factors you must consider to achieve predictable, wealth-preserving results in international tax and estate planning. You'll find out how to minimise taxes, ensure the desired disposition of property, protect confidentiality, maintain the security of the estate, and even manage assets in the event of incapacity of the principal. Published in looseleaf format and updated bi-annually, International Tax & Estate Planning is filled with insightful strategies for preserving the estate. Find out how to protect against nightmarish complexities of renvoi, forced heirship in civil law jurisdictions, and the negative impact of common law. You will also get expert tax-advantaged strategies for leveraging assets, such as use of a transient posture to reduce future taxes and protective devices for corporations based in financially attractive, but potentially unstable, foreign states.
Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Author : Robert L. Williams Publisher : Kluwer Law International Page : 0 pages File Size : 49,68 MB Release : 2014 Category : Law ISBN : 9789041149480
This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.
This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
"The global economic and financial crisis has created important needs for fiscal consolidation. This document analyses potential instruments to raise additional tax revenues from the financial sector. The first section reviews the current policy objectives related to the taxation of the financial sector. The second section sheds some light on the current tax treatment of the financial sector. The third section discusses potential tax instruments to reach the goals. The fourth and fifth section respectively assess the advantages and drawbacks of a Financial Transaction Tax and a Financial Activities Tax."--Editor.