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This book contains a critical evaluation of the nexus requirements for the taxation of non-residents' business income enshrined in the current rules of international tax law and provides a proposal that is more aligned with international tax policy benchmarks.
Income tax --- Double taxation. --- Double taxation --- International taxation (Double taxation) --- Taxation, Double --- Taxation --- Conflict of laws --- Foreign income, Taxation of --- Taxation of foreign income --- Law and legislation. --- Foreign income. --- Law and legislation --- Law --- Foreign income --- E-books --- Tax law
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This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.
Income tax --- Business enterprises, Foreign --- Aliens --- Double taxation --- Foreign income --- Taxation --- Law and legislation --- Double taxation. --- Law and legislation. --- Foreign income. --- Law --- General and Others --- Income tax - Foreign income --- Business enterprises, Foreign - Taxation - Law and legislation --- Aliens - Taxation - Law and legislation --- Noncitizens --- International taxation (Double taxation) --- Taxation, Double --- Conflict of laws --- Foreign income, Taxation of --- Taxation of foreign income
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For tax year 2011 (the most recent data available), an estimated 445,000 tax returns claimed the foreign earned income exclusion (FEIE), which is 0.3 percent of all individual tax returns filed. Taxpayers were able to exclude from taxable income about 30 billion in foreign earned income and housing costs, with about 45 percent excluding all or most of their foreign earned income. The FEIE reduces the tax liability of U.S. taxpayers working abroad even if they paid no foreign income taxes to another country. U.S. taxpayers in higher tax countries can eliminate their U.S. tax liability using the
Income tax -- United States -- History. --- Tax evasion -- United States -- History. --- Taxation -- United States -- History. --- Law - U.S. --- Law, Politics & Government --- Public Finance Laws - U.S. --- Income tax --- Foreign income. --- Foreign income, Taxation of --- Taxation of foreign income --- Foreign income --- E-books
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International Commercial Tax, 2nd edition takes account of the substantial developments of the last decade. With more than sixty percent new material, the book considers the outcomes of the OECD's BEPS project and the substantial consequential 2017 revisions of the OECD and UN Model tax treaties. With the continuing rise in the economic importance of non-OECD countries and the UK distancing itself from the EU, there has been a refocusing with less direct attention on UK domestic law and greater focus on the approaches of other significant countries, especially other common law jurisdictions. This provides greater flexibility as to how a particular point or issue is illustrated with practical examples. Greater attention is given to the UN Model, which is increasingly important. The book continues to compare the approach under model tax treaties with EU law and is updated with copious references and illustrations from the burgeoning jurisprudence of the EU Court.
International business enterprises --- Taxation --- Law and legislation. --- Income tax --- Double taxation. --- Double taxation --- Foreign income. --- Law and legislation --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business enterprises --- Corporations --- Joint ventures --- International taxation (Double taxation) --- Taxation, Double --- Conflict of laws --- Foreign income, Taxation of --- Taxation of foreign income
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Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.
International business enterprises --- Income tax --- Double taxation. --- Double taxation --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business enterprises --- Corporations --- Joint ventures --- International taxation (Double taxation) --- Taxation, Double --- Taxation --- Conflict of laws --- Foreign income, Taxation of --- Taxation of foreign income --- Law and legislation. --- Foreign income. --- Law and legislation --- Foreign income --- Taxation&delete& --- Law --- General and Others
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Tax law --- Double taxation. --- Taxation --- Conflict of laws --- International business enterprises --- Income tax --- Tax planning. --- Double imposition --- Droit fiscal --- Impôt --- Entreprises multinationales --- Impôt sur le revenu --- Planification fiscale --- Law and legislation --- Law and legislation. --- Foreign income. --- Droit international privé --- Impôts --- Droit --- Revenus étrangers --- Impôt --- Impôt sur le revenu --- Droit international privé --- Impôts --- Revenus étrangers --- Double taxation --- Tax planning --- Tax avoidance --- Tax saving --- Estate planning --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business enterprises --- Corporations --- Joint ventures --- Foreign income, Taxation of --- Taxation of foreign income --- International taxation (Double taxation) --- Taxation, Double --- Foreign income --- Taxation&delete&
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Double taxation --- Income tax --- International business enterprises --- Double imposition --- Impôt sur le revenu --- Entreprises multinationales --- Foreign income --- Taxation --- Law and legislation --- Revenus étrangers --- Impôts --- Droit --- 336.206 --- 336.214 --- 341.247 --- 348.5 --- AA / International- internationaal --- Foreign income, Taxation of --- Taxation of foreign income --- International taxation (Double taxation) --- Taxation, Double --- Conflict of laws --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business enterprises --- Corporations --- Joint ventures --- Taxation&delete& --- dubbele en meervoudige aanslag --- Belastingstelsel van de genootschappen --- Overeenkomsten inzake dubbele belasting en belastingsontduiking --- Belastingsrecht
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Tax law --- Belgium --- Belastingen --- Impôts --- Juridiction (Droit international) --- Jurisdiction (International law) --- Rechtspraak (Internationaal recht) --- 351.713*12 <493> --- Income tax --- -International business enterprises --- -Jurisdiction (International law) --- 336.2 <493> --- inkomstenbelasting --- fiscaal recht --- internationaal recht --- Domestic jurisdiction --- International jurisdiction --- Jurisdiction, Domestic --- Jurisdiction, International --- Arbitration (International law) --- International courts --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business enterprises --- Corporations --- Joint ventures --- Personal income tax --- Taxable income --- Taxation of income --- Direct taxation --- Internal revenue --- Progressive taxation --- Tithes --- Wages --- Inkomstenbelasting--België --- Foreign income --- Taxation --- -Law and legislation --- impot sur le revenu --- droit fiscal --- droit international --- International business enterprises --- Foreign income. --- Law and legislation. --- Jurisdiction (International law). --- 351.713*12 <493> Inkomstenbelasting--België --- Foreign income, Taxation of --- Taxation of foreign income --- Taxation&delete& --- Law and legislation
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Taxes --- International finance --- Taxation --- Capital levy --- Income tax --- International economic integration --- Foreign income --- 336.215.21 --- -International economic integration --- fiscalite --- impot sur le revenu --- revenus etrangers --- conventions fiscales internationales --- paradis fiscaux --- commerce mondial --- AA / International- internationaal --- 336.200 --- -Capital levy --- 336.2 --- Duties --- Fee system (Taxation) --- Tax policy --- Tax reform --- Taxation, Incidence of --- Finance, Public --- Revenue --- Common markets --- Economic integration, International --- Economic union --- International economic relations --- Personal income tax --- Taxable income --- Taxation of income --- Direct taxation --- Internal revenue --- Progressive taxation --- Tithes --- Wages --- Capital --- Capital taxes --- Levy on capital --- Property tax --- Negatieve belastingsinkomsten --- fiscaliteit --- inkomstenbelasting --- buitenlandse inkomsten --- internationale belastingverdragen --- belastingparadijzen --- wereldhandel --- Belastingstelsel: algemene naslagwerken en principes. --- Capital levy. --- International economic integration. --- Taxation. --- Foreign income. --- 336.215.21 Negatieve belastingsinkomsten --- Integration, International economic --- Markets, Common --- Union, Economic --- Foreign income, Taxation of --- Taxation of foreign income --- Belastingstelsel: algemene naslagwerken en principes --- Income tax - Foreign income
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The declining U.S. national saving rate has prompted economists and policymakers to ask, should the federal government encourage household saving, and if so, through which policies? In order to better understand saving programs, this volume provides a systematic and detailed description of saving policies in the G-7 industrialized nations: the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom. Each of the seven chapters focuses on one country and addresses a core set of topics: types of accumulated household savings and debt; tax policies toward capital income; saving in the form of public and private pensions, including Social Security and similar programs; saving programs that receive special tax treatment; and saving through insurance. This detailed summary of the saving incentives of the G-7 nations will be an invaluable reference for policymakers and academics interested in personal saving behavior.
Belasting --- Impôt --- Taxation --- CA / Canada --- DE / Germany - Duitsland - Allemagne --- FR / France - Frankrijk --- GB / United Kingdom - Verenigd Koninkrijk - Royaume Uni --- IT / Italy - Italië - Italie --- JP / Japan - Japon --- US / United States of America - USA - Verenigde Staten - Etats Unis --- 339.311.6 --- 339.311.1 --- 339.311.0 --- Beleid met betrekking tot het sparen (zie pensioensparen 332.834). --- Spaarneiging. --- Sparen: algemeenheden. --- Saving and investment --- Taxation. --- Government policy. --- Duties --- Fee system (Taxation) --- Tax policy --- Tax reform --- Taxation, Incidence of --- Taxes --- Accumulation, Capital --- Capital accumulation --- Capital formation --- Investment and saving --- Saving and thrift --- Finance, Public --- Revenue --- Capital --- Supply-side economics --- Wealth --- Investments --- Sparen en spaarzaamheid --- Government policy --- Saving and thrift - Government policy. --- Saving and investment - Government policy. --- Sparen: algemeenheden --- Spaarneiging --- Beleid met betrekking tot het sparen (zie pensioensparen 332.834) --- insurance, saving, tax shelters, social security, pension, retirement, capital income, taxation, debt, household savings, united kingdom, japan, italy, germany, france, canada, g-7 nations, finance, economics, nonfiction, thrift, investment, policy, government, inflation, poverty, wealth, aging, inequity, welfare, intervention, regulation, 401k, ira.
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