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Author | : United States. Congress. House. Committee on Energy and Commerce. Subcommittee on Health |
Publisher | : |
Total Pages | : 240 |
Release | : 2008 |
Genre | : Cosmetics |
ISBN | : |
Download Discussion Draft of the Food and Drug Administration Globalization Act Legislation Book in PDF, ePub and Kindle
Author | : United States. Congress. Senate. Committee on Indian Affairs (1993- ) |
Publisher | : |
Total Pages | : 120 |
Release | : 2010 |
Genre | : Technology & Engineering |
ISBN | : |
Download Discussion Draft of the Indian Energy Promotion and Parity Act of 2010 Book in PDF, ePub and Kindle
Author | : |
Publisher | : |
Total Pages | : 128 |
Release | : 2012 |
Genre | : |
ISBN | : |
Download The American Energy Initiative, Part 7: Discussion Draft of H.R..., Serial No. 112-47, May 13, 2011, 112-1 Hearing, *. Book in PDF, ePub and Kindle
Author | : United States. Congress. House. Committee on Ways and Means |
Publisher | : |
Total Pages | : 444 |
Release | : 1990 |
Genre | : Estates (Law) |
ISBN | : |
Download "Discussion Draft" Relating to Estate Valuation Freezes Book in PDF, ePub and Kindle
Author | : United States. Congress. House. Committee on Energy and Commerce. Subcommittee on Energy and Air Quality |
Publisher | : |
Total Pages | : 88 |
Release | : 2006 |
Genre | : Technology & Engineering |
ISBN | : |
Download Discussion Draft on the Pipeline Safety Improvement Act Reauthorization and H.R. 5782, the Pipeline Safety Improvement Act of 2006 Book in PDF, ePub and Kindle
Author | : United States. Congress. House. Committee on Energy and Commerce. Subcommittee on Energy and Power |
Publisher | : |
Total Pages | : 256 |
Release | : 2011 |
Genre | : Energy development |
ISBN | : |
Download The American Energy Initiative: Discussion drafts of H.R Book in PDF, ePub and Kindle
Author | : |
Publisher | : |
Total Pages | : 276 |
Release | : 1988 |
Genre | : Criminal procedure |
ISBN | : |
Download United States Sentencing Commission Discussion Materials on Organizational Sanctions Book in PDF, ePub and Kindle
Author | : Angelika Meindl-Ringler |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 458 |
Release | : 2016-06-07 |
Genre | : Law |
ISBN | : 9041168397 |
Download Beneficial Ownership in International Tax Law Book in PDF, ePub and Kindle
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 book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – 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 principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to 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 will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
Author | : United States. Congress. Senate. Committee on Labor and Human Resources |
Publisher | : |
Total Pages | : 86 |
Release | : 1997 |
Genre | : Business & Economics |
ISBN | : |
Download Tobacco Settlement Book in PDF, ePub and Kindle
Author | : United States. Congress. Joint Committee on Taxation |
Publisher | : |
Total Pages | : 44 |
Release | : 1990 |
Genre | : Inheritance and transfer tax |
ISBN | : |
Download Present law and proposals relating to federal transfer tax consequences of estate freezes Book in PDF, ePub and Kindle