U.S. Tax Treaties
Author | : United States. Internal Revenue Service |
Publisher | : |
Total Pages | : 12 |
Release | : 1980 |
Genre | : Aliens |
ISBN | : |
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Author | : United States. Internal Revenue Service |
Publisher | : |
Total Pages | : 12 |
Release | : 1980 |
Genre | : Aliens |
ISBN | : |
Author | : United States. Congress. Joint Committee on Internal Revenue Taxation |
Publisher | : |
Total Pages | : 1532 |
Release | : 1962 |
Genre | : Aliens |
ISBN | : |
Author | : |
Publisher | : |
Total Pages | : 52 |
Release | : 1981 |
Genre | : Capital gains tax |
ISBN | : |
Author | : United States |
Publisher | : Springer |
Total Pages | : 678 |
Release | : 1991-02-05 |
Genre | : Business & Economics |
ISBN | : |
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 | : |
Publisher | : |
Total Pages | : 52 |
Release | : 1998 |
Genre | : Aliens |
ISBN | : |
Author | : Richard L. Doernberg |
Publisher | : |
Total Pages | : 444 |
Release | : 1999 |
Genre | : Double taxation |
ISBN | : |
Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Author | : Arvid Aage Skaar |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 957 |
Release | : 2020-06-19 |
Genre | : Law |
ISBN | : 9403520647 |
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Author | : United States |
Publisher | : |
Total Pages | : 2368 |
Release | : 1965 |
Genre | : Double taxation |
ISBN | : |
Author | : United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight |
Publisher | : |
Total Pages | : 182 |
Release | : 1980 |
Genre | : Double taxation |
ISBN | : |
Author | : Kuldeep Sharma |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 352 |
Release | : 2021-04-22 |
Genre | : Law |
ISBN | : 9403532610 |
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.