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Global Perspectives on Income Taxation Law by Reuven Shlomo Avi-Yonah,Nicola Sartori,Omri Marian Pdf
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
Global Perspectives on Income Taxation Law by Reuven Shlomo Avi-Yonah Pdf
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
Global Perspectives on E-Commerce Taxation Law by Subhajit Basu Pdf
In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.
Taxation and Migration by Reuven S. Avi-Yonah,Joel Slemrod Pdf
Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base decisions. Nowhere is this necessity more pressing than in the development of relevant tax rules that meet the basic requirements of efficiency and equity. Moreover, the ascent of the so-called emerging economies coupled with the stagnation of the richest economies of the world implies reform of the current competition-based international tax regime and the adoption of a more cooperative paradigm. This important and timely book, for the first time in such depth, explores such aspects of the problem as the following: - migration for tax reasons, especially corporate "inversions" (change in corporate residence for tax purposes); - tax consequences related to individuals who receive free or subsidized education in one country and profit from it in another; - taxing cross-border retirement income; and - migration-related aspects of tax preferential treatment of the elderly. With particular emphasis on the effects and opportunities created by the changing international tax regime - and with attention to the role of tax treaties and recent court cases - chapters by well known tax experts present evidence on the consequences of migration in all its facets and simulate the effects of several recently enacted and proposed changes in tax law in European countries, the United States, and other jurisdictions. The grounded propositions and recommendations offered in this deeply informed book will allow policymakers to draft tax-residence rules that minimize distortion and promote fairness. The book will also be of interest to tax law practitioners and other tax specialists, migration experts, and academics investigating one of the crucial political issues of our time.
Author : Hugh J. Ault,Brian J. Arnold Publisher : Kluwer Law International B.V. Page : 594 pages File Size : 51,7 Mb Release : 2010-01-01 Category : Business & Economics ISBN : 9789041132048
Comparative Income Taxation by Hugh J. Ault,Brian J. Arnold Pdf
The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.
Global Perspectives on Constitutional Law by Vikram Amar,Mark V. Tushnet Pdf
An ideal supplement for professors who wish to incorporate comparative law into their constitutional law courses, Global Perspectives on Constitutional Law introduces students to the various ways that nations other than the United States resolve contemporary constitutional questions. Covering both structural issues and individual rights, the book offers a wide but select range of readings on interesting constitutional issues in sixteen accessible chapters. Each brief chapter presents foreign case materials on a particular constitutional topic along with notes and questions that further illuminate the comparisons between U.S. constitutional law and that of other nations. Featuring selections by expert contributors from a variety of ideological and demographic backgrounds, the volume is designed to encourage students to reexamine and deepen their understanding of U.S. constitutional law in light of the alternatives offered by other systems.Features*Modular design of chapters allows instructors to pick and choose which topics they use for comparative study*Brief chapters can be easily integrated into relevant class discussions*Chapters authored by top constitutional law scholars who frame the cases with introductory and concluding comments*Covers a broad range of contemporary constitutional issues including property rights, abortion rights, regulation of hate speech, regulation of campaign finance, and religious freedom
Non-Discrimination in Tax Treaties by Pasquale Pistone,Dennis Manolito Weber Pdf
Recoge: 1: Nationality Non-Discrimination and Article 24 OECD Model: Perennial Issues, Recent Trends and New Approaches - 2: Non-Discrimination on the Basis of Nationality in IIAs: A Latin American Tax Perspective - 3: Interest Deduction Limitations: When To Apply Articles 9 and 24(4) of the OECD Model? - 4: Revisiting the Application of the Capital Ownership Non-Discrimination Provision in Tax Treaties - 5: Non-Discrimination in Tax Treaties – Art. 24(4) and (5) OECD MC: A Russian Approach to Tax Treaty Interpretation - 6: Non-Discrimination and Harmful Tax Competition under WTO Law and Article 24 of the OECD Model - 7: Non-Discrimination: Can the EU Learn from the OECD Model Convention and Vice Versa? - 8: Non-Discrimination à la Cour: The ECJ’s (Lack of) Comparability Analysis in Direct Tax Cases - 9: Discriminatory Taxation and the European Convention on Human Rights.
Foundations of International Income Taxation by Michael J. Graetz Pdf
An overview of international income tax law, the institutions that shape that law and the underlying policy debates, with numerous extracts from the scholarly literature on the subject.
This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation. The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts. Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area.
Income Taxation and International Mobility by Jagdish N. Bhagwati,John Douglas Wilson Pdf
Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to "tax the brain drain."Today millions of people work in countries where they are not citizens. Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to tax the brain drain. The contributors, who include many of the leading theorists of international economics and public finance, look at how the difficult question of how horizontal equity is to be defined - between nationals at home and abroad or between nationals abroad and foreign citizens abroad - and tackle such questions as Should a country exercise income tax jurisdiction over its citizens abroad? If so, in what way? Is it practical to do so? The issues that these questions raise are complex, lying on the interface of politics, sociology, and economics. Income Taxation and International Mobility breaks significant new ground by analyzing these questions and building on the modern theory of optimal income taxation to examine the consequences of the possibility of outmigration on the appropriate exercise and design of income tax jurisdiction on those who live outside their native country. Theoretical analyses are presented in six chapters by the editors and by James Mirrlees, William Baumol, and Koichi Hamada. The well known tax law expert, Richard Pomp, examines the Philippines experience in taxing citizens abroad. The editors provide a substantial introduction that synthesizes the book's major analytical approaches and conclusions, and Richard Musgrave provides an insightful view of the issues in his Foreword.
International Taxation of Trust Income by Mark Brabazon Pdf
This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Tax law is political. This book highlights and explains the major themes and methodologies of a group of scholars who challenge the traditional claim that tax law is neutral and unbiased. The contributors to this volume include pioneers in the field of critical tax theory, as well as key thinkers who have sustained and expanded the investigation into why the tax laws are the way they are and what impacts tax laws have on historically disempowered groups. This volume, assembled by two law professors who work in the field, is an accessible introduction to this new and growing body of scholarship. It is a resource not only for scholars and students in the fields of taxation and economics, but also for those who engage with critical race theory, feminist legal theory, queer theory, class-based analysis, and social justice generally. Tax is the one area of law that affects everyone in our society, and this book is crucial to understanding its impact.
Global Perspectives on E-Commerce Taxation Law by Dr Subhajit Basu Pdf
In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.
