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Author : Boris I. Bittker
Publisher : Unknown
Page : 102 pages
File Size : 44,8 Mb
Release : 1991
Category : Aliens
ISBN : IND:30000086970948
Author : B.I. Bittker
Publisher : Unknown
Page : 128 pages
File Size : 50,6 Mb
Release : 2015
Category : Electronic
ISBN : 0791392589
Author : Jon E. Bischel,Robert Feinschreiber
Publisher : Unknown
Page : 586 pages
File Size : 52,7 Mb
Release : 1985
Category : Conflict of laws
ISBN : UCAL:B4316289
Comprehensive overview of the Unisted States tax laws that affect international business, including international trade, investment, and finance. The various chapters consider jurisdiction to tax, source of income, deductions, organization of foreign operations, forming a foreign corporation, foreign tax credit, controlled foreign corporations, restructuring the foreign enterprise, characterization of gains and losses, export structures (DISC and FSC), possessions corporations, Americans overseas, general rules for foreign activitities in the USA, foreign individuals, foreign corporations, foreign taxes and related considerations, intercompany transactions, tax treaties, general tax avoidance provisions, international tax compliance, tax consequences of boycott involvement, state taxation of multinational operations, intellectual property, real estate, international leasing, exporting, importing, manufacturing, and use of international funds,
Author : Boris I. Bittker,Lawrence Lokken
Publisher : Unknown
Page : 128 pages
File Size : 41,7 Mb
Release : 2018
Category : Aliens
ISBN : 1508301654
Author : Boris Bittker
Publisher : Unknown
Page : 128 pages
File Size : 47,9 Mb
Release : 2013
Category : Electronic
ISBN : 150831134X
Author : Lawrence Lokken
Publisher : Unknown
Page : 88 pages
File Size : 54,9 Mb
Release : 2011
Category : Aliens
ISBN : 0791379388
Author : Wolfgang Schön,Kai A. Konrad
Publisher : Springer Science & Business Media
Page : 306 pages
File Size : 50,6 Mb
Release : 2012-02-15
Category : Law
ISBN : 9783642259807
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Author : Boris J. Bittker,Lawrence Lokken,Michelle Wilson
Publisher : Warren Gorham & Lamont
Page : 1112 pages
File Size : 51,6 Mb
Release : 1998-01-01
Category : Aliens
ISBN : 0791335127
Author : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 44,8 Mb
Release : 2019-01-03
Category : Law
ISBN : 9789041190215
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Author : Richard L. Doernberg
Publisher : West Academic Publishing
Page : 0 pages
File Size : 41,8 Mb
Release : 2007
Category : Aliens
ISBN : 0314163107
This book provides an introduction to the US law of international taxation. After an introduction to the fundamentals of US international taxation and the source rules, this book addresses investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profits tax and the provisions affecting foreign investment in US real estate. Also included are chapters on US income tax treaties and filing withholding and reporting requirements. The last part of the book is directed at investment and business activities of US citizens, residents and domestic corporations outside the US. The centerpiece is a consideration of the US foreign tax credit. Intercompany pricing, controlled foreign corporations, the treatment of foreign currency, and international tax-free transactions are discussed, as well as tax arbitrage.
Author : Richard L. Doernberg
Publisher : West Academic Publishing
Page : 628 pages
File Size : 53,9 Mb
Release : 2009
Category : Aliens
ISBN : UCSC:32106019876561
Offers a concise exposition of the United States tax laws involved in international business and investment transactions.
Author : Yariv Brauner
Publisher : Edward Elgar Publishing
Page : 464 pages
File Size : 51,5 Mb
Release : 2020-12-25
Category : Electronic
ISBN : 1788975367
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians' agendas. Expert international contributors present an array of perspectives and approaches to research in the field, but all consider the necessity of fundamental reforms. The Research Handbook offers a reappraisal of the foundations and core concepts of the international tax regime, highlighting the need to adjust nineteenth and twentieth century solutions to the challenges of the twenty-first century. Chapters look at the challenges of embracing globalization, the interdependence of world economics, the ensuing impossibility of truly unilateral international tax policy, and the need to accommodate the expanding cast of players on the political map. With a variety of paths to reform suggested throughout, this Research Handbook will prove an invigorating read for law scholars working on taxation law as well as practitioners and policy makers seeking ways to improve, or navigate, the current state of affairs with international tax law.
Author : Lynne Oats
Publisher : Bloomsbury Publishing
Page : 773 pages
File Size : 51,5 Mb
Release : 2021-09-30
Category : Business & Economics
ISBN : 9781526519566
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Author : Boris I. Bittker,Lawrence Lokken
Publisher : Unknown
Page : 128 pages
File Size : 41,9 Mb
Release : 1995
Category : Aliens
ISBN : 079132382X
Author : Ulrich Schreiber
Publisher : Springer Science & Business Media
Page : 179 pages
File Size : 47,6 Mb
Release : 2013-01-30
Category : Business & Economics
ISBN : 9783642363061
The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.