International Taxation Of Cross Border Leasing Income

Author : Amar Mehta
Publisher : IBFD
ISBN 13 : 9076078718
Total Pages : 307 pages
Book Rating : 4.17/5 ( download)

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Download or read book International Taxation of Cross-border Leasing Income written by Amar Mehta and published by IBFD. This book was released on 2005 with total page 307 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.

Author : Craig Elliffe
Publisher :
ISBN 13 : 9781988504995
Total Pages : 948 pages
Book Rating : 4.96/5 ( download)

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Download or read book International and Cross-border Taxation in New Zealand written by Craig Elliffe and published by . This book was released on 2018 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by international tax law specialist Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand's international tax law and double taxation agreements and transfer pricing regime. The book is designed to provide readers with an understanding of the legal principles and concepts which underpin international tax law and cross-border transactions and with practical guidance designed to assist them to navigate their way through this complex topic. It begins with an introductory chapter explaining the history and concept of international taxation and the way in which New Zealand and other nations deal with international taxation transactions. The next four chapters provide comprehensive coverage of residence-base taxation; source-based taxation; and taxation of source based income. The final two chapters deal with double tax agreements and allocation of profits (thin capitalisation).

Author : Dieter Endres
Publisher :
ISBN 13 : 9789041145567
Total Pages : 0 pages
Book Rating : 4.67/5 ( download)

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Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

Author : Michael S. Schadewald
Publisher :
ISBN 13 : 9780808040842
Total Pages : 0 pages
Book Rating : 4.47/5 ( download)

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Download or read book Practical Guide to U.S. Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

Author : Angelika Meindl-Ringler
Publisher : Kluwer Law International
ISBN 13 : 9789041168337
Total Pages : 0 pages
Book Rating : 4.38/5 ( download)

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Download or read book Beneficial Ownership in International Tax Law written by Angelika Meindl-Ringler and published by Kluwer Law International. This book was released on 2016 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Series on International Taxation Volume 58 Beneficial Ownership in International Tax Law compares the use and interpretation of beneficial ownership, both current and historical, in a wide range of national jurisdictions and the EU. In International Tax Law, the term 'beneficial ownership' refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This is a book dedicated to establishing how beneficial ownership should ideally be interpreted ultimately shedding a clearer light than has heretofore been available on the meaning of the term. What's in this book: The author on thorough analysis of the application of beneficial ownership touches on the following aspects: historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; rules of double taxation conventions; application of the OECD's Action Plan on Base Erosion and Profit-Shifting (BEPS); the problem of so-called white income; use of the substance-over-form princip≤ attribution-of-income rules; and the role of agents, nominees and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in the context of a domestic law and treaty in numerous jurisdictions - with particular emphasis on the United Kingdom, Australia, the United States and Germany - is a major feature of the presentation. Furthermore, a comprehensive coverage of how the concept of beneficial ownership has developed over the past half-century is discussed. How this will help you: This book provides thorough guidance in determining whether a person claiming tax treaty benefits is the true owner - and which parties are excluded from treaty benefits and to what extent. This book helps in developing a logical, easy-to-apply practical approach to beneficial ownership. Highlights of complex issues and important jurisdictional differences in the interpretation of beneficial ownership ensure an in-depth understanding of the concept of beneficial ownership, which serves to be of immeasurable value to lawyers, tax authorities, policymakers and other professionals working with taxable international transactions of any kind.

Author : Joseph Isenbergh
Publisher :
ISBN 13 :
Total Pages : 692 pages
Book Rating : 4.70/5 ( download)

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Download or read book International Taxation written by Joseph Isenbergh and published by . This book was released on 1990 with total page 692 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive guide on the tax consequences of inbound transactions.

Author : Holly Lanford
Publisher : Nova Science Publishers
ISBN 13 : 9781633219762
Total Pages : 0 pages
Book Rating : 4.63/5 ( download)

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Download or read book U.S. International Tax System written by Holly Lanford and published by Nova Science Publishers. This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: On July 22, 2014, the Senate Committee on Finance held a public hearing on the taxation of cross-border income. This book, prepared by the staff of the Joint Committee on Taxation for the hearing, includes a description of present law, background on recent global activity related to the taxation of cross-border income, and descriptions and a comparison of recent proposals to reform the U.S. international tax system.

Author : Paul R. McDaniel
Publisher :
ISBN 13 : 9789041123602
Total Pages : 0 pages
Book Rating : 4.01/5 ( download)

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Download or read book Introduction to United States International Taxation written by Paul R. McDaniel and published by . This book was released on 2005 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2005 edition of this well-known reference work for the tax community 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. 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 ten specific aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts and estates, 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; the general inter-company 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. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act . 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.

Author : Mr.Victor Thuronyi
Publisher : International Monetary Fund
ISBN 13 : 9781557755872
Total Pages : 534 pages
Book Rating : 4.76/5 ( download)

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Download or read book Tax Law Design and Drafting, Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Author : Christoph Spengel
Publisher : Springer Science & Business Media
ISBN 13 : 3642284337
Total Pages : 130 pages
Book Rating : 4.35/5 ( download)

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Download or read book Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income written by Christoph Spengel and published by Springer Science & Business Media. This book was released on 2012-03-13 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt: The study conducted by the Centre of European Economic Research (ZEW), the University of Mannheim and Ernst & Young contributes to the ongoing evaluation of the proposal for a Draft Council Directive on a Common Consolidated Corporate Tax Base (CC(C)TB) released by the European Commission on March 16, 2011. For the first time, details on the determination of taxable income under the proposed Council Directive are compared to prevailing corporate tax accounting regulations in all 27 Member States, Switzerland and the US. The study presents evidence on the scope of differences and similarities between national tax accounting regulations and the Directive’s treatment in a complete, yet concise form. Based on this comprehensive comparison, it goes on to discuss remaining open questions and adjustments needed if the Directive is to be implemented in national tax law. Readers seeking a basis for taking an active part in the public debate will find a valuable source of information and a first impression of how the proposed CC(C)TB would affect corporate tax burdens in the European Union.