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Author : United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
Publisher : Unknown
Page : 964 pages
File Size : 44,9 Mb
Release : 2008
Category : Dividends
ISBN : PSU:000066748922
Author : Guglielmo Maisto,International Bureau of Fiscal Documentation
Publisher : IBFD
Page : 1093 pages
File Size : 50,7 Mb
Release : 2012
Category : Corporations
ISBN : 9789087221393
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Author : OECD
Publisher : OECD Publishing
Page : 78 pages
File Size : 48,8 Mb
Release : 2021-06-17
Category : Electronic
ISBN : 9789264572874
First published in 2017, Fighting Tax Crime - The Ten Global Principles is the first comprehensive guide to fighting tax crimes. It sets out ten essential principles covering the legal, institutional, administrative, and operational aspects necessary for developing an efficient and effective system for identifying, investigating and prosecuting tax crimes, while respecting the rights of accused taxpayers.
Author : Canada. Royal Commission on Taxation
Publisher : Unknown
Page : 146 pages
File Size : 54,9 Mb
Release : 1967
Category : Corporations
ISBN : STANFORD:36105062970285
Author : Richard Löfqvist
Publisher : Department of Economics Uppsala University
Page : 145 pages
File Size : 45,8 Mb
Release : 2001-01-01
Category : Dividends
ISBN : 9187268620
Author : CCH Canadian Limited
Publisher : Don Mills, Ont. : CCH Canadian
Page : 358 pages
File Size : 53,5 Mb
Release : 1987
Category : Corporations
ISBN : STANFORD:36105044083397
The 1987 tax reform package considered.
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 12 pages
File Size : 46,7 Mb
Release : 2024-06-29
Category : Electronic
ISBN : STANFORD:36105127904980
Author : Peter Harris
Publisher : Cambridge University Press
Page : 651 pages
File Size : 45,5 Mb
Release : 2013-03-07
Category : Business & Economics
ISBN : 9781107033535
A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.
Author : Xavier Oberson,Howard R. Hull
Publisher : IBFD
Page : 457 pages
File Size : 52,8 Mb
Release : 2011
Category : Double taxation
ISBN : 9789087220983
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author : Fraser Institute (Vancouver, B.C.)
Publisher : The Fraser Institute
Page : 36 pages
File Size : 53,7 Mb
Release : 2001
Category : Capital gains tax
ISBN : 9780889751897
Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 40,9 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827
Author : Richard S Collier
Publisher : Oxford University Press
Page : 368 pages
File Size : 53,7 Mb
Release : 2020-09-01
Category : Business & Economics
ISBN : 9780192603470
Banks seem all too often involved in cases of misconduct, particularly involving the exploitation of tax systems. Banking on Failure explains why and how banks "game the system", accounting for these misconduct cases and analysing the wider implications for financial markets and tax systems. Banking on Failure: Cum-Ex and Why and How Banks Game the System explains why banks design and use structured products to exploit tax systems. It describes one of the biggest and most complex cases - the "cum-ex" scandal - in which hundreds of banks and funds from across the globe participated in the raid on the public exchequers of a number of countries, with losses in the tens of billions of euros. The book then draws on the significance of this case study, and what this tells us about modern banks and their interactions with tax systems. Banking on Failure demonstrates why the exploitation of tax systems by banks is an inevitable feature of the financial markets landscape, and suggests possible responses.
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 12 pages
File Size : 45,5 Mb
Release : 1980
Category : Aliens
ISBN : UFL:31262085185857
Author : United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher : Unknown
Page : 1510 pages
File Size : 42,8 Mb
Release : 1962
Category : Double taxation
ISBN : UOM:39015023071254
Author : Brian J. Arnold,Jinyan Li,Daniel Sandler,Canada. Technical Committee on Business Taxation
Publisher : The Committee
Page : 60 pages
File Size : 52,6 Mb
Release : 1996
Category : Business enterprises
ISBN : UIUC:30112039983876
The report deals with selected aspects of the tax treatment of foreign-source income in Canada, Australia, France, Germany and the US. It emphasizes the structural features of each country's tax system with respect to the taxation of foreign-source income derived by resident corporations. In particular, the report focuses on the taxation of dividends from foreign corporations, controlled foreign corporation (CFC) rules, foreign investment funds rules, and source of income and expense rules.
