[PDF] Us Tax Treaties eBook

Author : United States
Publisher : Springer
Page : 678 pages
File Size : 39,61 MB
Release : 1991-02-05
Category : Business & Economics
ISBN :

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This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.

Author : Richard L. Doernberg
Publisher :
Page : 444 pages
File Size : 41,44 MB
Release : 1999
Category : Double taxation
ISBN :

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Text originally prepared for a class. Includes course outline, assignments and supporting materials.

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
Page : 352 pages
File Size : 46,77 MB
Release : 2021-04-22
Category : Law
ISBN : 9403532610

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The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self-contained book offers an unmatched article-by-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply. Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in-depth discussion of the following and more: how specific gaps in existing bilateral tax treaties are addressed by the MLI; positions taken by selected jurisdictions and their impact on treaties; compatibility clauses, notification clauses, opting-in mechanisms, alternative provisions, and reservations; experiences in the course of implementation of the MLI; misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI; interaction between the principal purpose test and simplified limitation on benefits; improving dispute resolution; and meaning of the phrases ‘on or after’, ‘other taxes’, and interpretational issues in entry into effect provisions. Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy-to-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.

Author : Juan Angel Becerra
Publisher : IBFD
Page : 299 pages
File Size : 10,53 MB
Release : 2007
Category : Canada
ISBN : 9087220197

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This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.