[PDF] Three Essays On International Corporate Income Taxation eBook

Author : Dhruv Sanghavi
Publisher : Bloomsbury Publishing
Page : 530 pages
File Size : 12,53 MB
Release : 2020-12-21
Category : Business & Economics
ISBN : 9390176867

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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 : Michael J. Graetz
Publisher : Yale Law Library
Page : 536 pages
File Size : 17,78 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.

Author : Peggy B. Musgrave
Publisher : Edward Elgar Publishing
Page : 492 pages
File Size : 50,51 MB
Release : 2002
Category : Business & Economics
ISBN :

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The globalization of economies and the vast expansion of foreign investment have greatly increased the problems of international taxation. Musgrave (economics, emerita, U. of California-Santa Cruz) argues that cross- border tax issues should not be left to the destructive forces of tax competition but should be handled through coordinating measures of international tax agreements, thereby minimizing tax distortions in the international flow of capital while leaving countries free to determine their own tax structures. The 22 essays are drawn from a variety of publications including technical papers prepared for the government and the World Bank, books, The Columbia Journal of World Business, Tax Law Review, and other publications. Annotation copyrighted by Book News, Inc., Portland, OR

Author : Michael Love
Publisher :
Page : 0 pages
File Size : 16,19 MB
Release : 2023
Category :
ISBN :

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Business taxation, by affecting the costs of certain behaviors of firms, owners, or their counterparties, can trigger potentially substantial changes in real activity, such as changes in inputs or production processes. But it can also prompt avoidance responses--such as legal restructuring or changes in tax reporting--that may have important effects on efficiency and distribution. Understanding such responses is thus critical for enacting efficient and well-informed tax policy.In this dissertation I investigate the real and avoidance responses at the intersection of several important topics in businesses taxation, namely capital taxation, taxation of passthrough entities, international taxation, and corporate taxation. My research sheds new light on our understanding of US business taxation by employing a variety of empirical methods to (1) develop new explanations for persistent puzzles in the literature, (2) fill knowledge gaps in the current body of business tax research, and (3) draw attention to new issues that have so far received little attention by public finance economists.In Chapter 1, I investigate financing and investment responses by corporations to a change in capital taxation, presenting results that help resolve an existing conflict among empirical findings in the public finance literature. I estimate that dividend taxes, by impacting the cost of equity financing, have large effects on the financing, investment, and real outcomes of many US public firms. But--in contrast with economists' longstanding focus on capital investment outcomes--I find these responses are mostly from smaller, cash-constrained firms through “non-capital” investment channels: R&D and operating expenditures. Exploiting a quasi-experiment that tracks financing and expenditure responses to the 2003 dividend tax cut, I estimate a large, immediate, and sustained increase in average equity financing (+86% ± 11%) by these firms, reflecting a high elasticity to the cost of capital. Responsive firms put the cash substantially toward operating expenditures and R&D, rather than tangible investment. I also find higher job growth and long-run sales among the responsive firms. These results make sense, reconciling mixed evidence in recent research: because dividend taxes affect the cost of equity financing, the firms impacted most are those that actually rely on equity financing--smaller, often unprofitable, less capital-intensive firms who invest heavily in “non-capital” pathways.In Chapter 2, I describe and estimate tax avoidance behavior that uses complex entity structures involving partnerships and tax havens to exploit discrepancies in tax treatment of capital income across jurisdictions. I also address a significant missing piece of knowledge in the public finance literature: where partnership income goes. Partnerships are the fastest growing class of business entity in the United States and represent over one third of reported business income, but due to their legal complexity, data quality, and opaque nature economists have not yet been able to identify where a sizeable portion of this income goes. In this paper, I use US federal tax records from 2005-2019 to compile a comprehensive analysis covering 99% of the income flowing to the owners of partnerships. I find that a much larger portion goes to foreign owners than previously thought, and that most of this amount goes to tax havens--over USD1 trillion since 2011. The majority of these flows likely face zero tax in either the US or in the tax haven. The evidence I present suggests a prevalent use of entity arrangements by investment firms that shield investors from tax and reporting through “blocker structures,” predominantly in the Cayman Islands. Evidence also suggests a substantial increase in income reported after the enactment of Foreign Account Tax Compliance Act (FATCA). In Chapter 3, I investigate the degree to which corporations can manipulate their accounting of expenses to avoid taxes, and what effects this has on the corporate tax base. The investigation exploits a unique corporate tax reform in Texas that replaced a 4.5% profits tax with a broader 1% gross revenue tax and that eliminated almost all deductions, but still permitted corporations to deduct one of two categories of expenses: cost of goods sold (COGS) or total worker compensation. Data from federal corporate income tax returns makes it possible to estimate the effects of the reform, as data are consistent across years and harmonized across states. Strong evidence reveals a very large avoidance response for COGS but not for compensation: corporations reduced the tax base roughly 4% by reclassifying non-deductible expenses into COGS (with a large elasticity of roughly -5 ± 1), but there is little reclassification into compensation. These findings reveal the potentially very large but also highly context-specific nature of accounting reclassification responses. Given that numerous states have some form of gross receipts tax and that there is currently wide discussion of measures to broaden corporate tax bases by incorporating accounting measures, these findings offer important considerations for policymakers and tax authorities when designing, scoring, and enforcing corporate tax changes.

Author : Neil Bruce
Publisher : Routledge
Page : 138 pages
File Size : 36,37 MB
Release : 2021-12-20
Category : Business & Economics
ISBN : 1000385299

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This book, first published in 1984, examines the use of simple general equilibrium models in analysing the effects of taxes. The replacement of the earlier partial equilibrium approach has yielded numerous insights and conclusions, and these are examined here alongside the simple general equilibrium reasoning.