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Author : James R. Hines Publisher : University of Chicago Press Page : 285 pages File Size : 41,8 Mb Release : 2009-02-15 Category : Business & Economics ISBN : 9780226341750
International Taxation and Multinational Activity by James R. Hines Pdf
Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe.
Author : Martin Feldstein,James R. Hines,R. Glenn Hubbard Publisher : University of Chicago Press Page : 338 pages File Size : 55,8 Mb Release : 2007-12-01 Category : Business & Economics ISBN : 9780226241876
The Effects of Taxation on Multinational Corporations by Martin Feldstein,James R. Hines,R. Glenn Hubbard Pdf
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
The International Taxation of Multinational Enterprises in Developed Countries by J. D. R. Adams,John Whalley Pdf
Monograph designed to outline the basic features of the tax treatment of multinational enterprises in developed countries and to present an evaluation of both present and alternative arrangements.
International Taxation of Manufacturing and Distribution by John Abrahamson Pdf
The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.
Corporate Taxation in the Global Economy by International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept. Pdf
The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities.
International Taxation of Banking by John Abrahamson Pdf
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
The International Taxation System by Andrew Lymer,John Hasseldine Pdf
International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Impact of International Taxation on FDI Location Choice by Alex Knauer Pdf
Seminar paper from the year 2006 in the subject Economics - Finance, grade: 1,3, University of Duisburg-Essen (Mercator School of Management), course: Internationalisierung von Unternehmen, 19 entries in the bibliography, language: English, abstract: Foreign direct investment has often been of great importance for developing countries and countries in transition. These countries develop various strategies to attract FDI, one of which includes the taxation attractiveness. This paper deals with the impact of international taxation on investment location choice of multinational firms. General aspects of taxation of the FDI destination country and the source country are looked close upon. Such general tax factors like corporate income tax rate, indirect taxes and tax law transparency, as well as tax incentives and taxation in the investor's home country, play an important role for a multinational's investment location decision, especially for the decision of footloose industries like export-oriented firms or manufacturing companies. Further, bilateral tax treaties including provisions of foreign tax credits, exemptions and tax savings affect the investor's tax planning, since they may alleviate or completely eliminate the problem of double taxation. Tax avoidance is also an important factor described in the paper. High tax rates, tax incentives and tax treaties may encourage multinational firms to use tax avoidance strategies in order to qualify for tax incentives or extend received ones, or to carry out profit reallocations.
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option by Richard Krever Pdf
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
Significant Current Issues in International Taxation by Ahmed Riahi-Belkaoui Pdf
Multinational corporations face different tax systems in different countries that require careful tax planning. A systematic approach is needed to minimize and avoid unnecessary business taxes. Some core issues of international taxation are part of a successful corporate tax plan in an international context. The first issue is a good understanding and appreciation of the principles of international taxation that include the different philosophies of taxation, the different kinds of taxes, the different tax systems, the different tax treaties and potential tax havens. The second issue is a thorough understanding of U.S. taxation of foreign income to avoid double taxation and the computation of foreign tax credits. The third issue is the choice of a transfer pricing method and the compliance with tax regulations on both the transfer of tangible and intangible assets. The fourth issue is the intelligent use of tax vehicles for exporting which can generate substantial savings and reduce the effective tax rate and involve the choice between the interest-charge domestic international sales corporation and the foreign sales corporation. A final issue is the efficient use of value-added taxation for activities taking place outside the U.S., and a new appreciation of the potential of this form of taxation for the United States. Practicing accountants, academics, business executives, students, legislators, and others who want a better understanding of the complex issues of international taxation will be interested in this book.
Fixing U.S. International Taxation by Daniel N. Shaviro Pdf
Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Research Handbook on International Taxation by Yariv Brauner Pdf
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.
International Taxation in a Nutshell by Richard L. Doernberg Pdf
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.
International Taxation in a Nutshell by Mindy Herzfeld Pdf
This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated to address the fundamental changes to the U.S. international tax rules introduced by the 2017 tax act, including interpretive regulatory guidance. It also includes discussion of interaction between U.S. tax rules and global tax changes brought about by recent OECD developments as they affect U.S. taxpayers. In addition to providing a survey of the technical rules, the book also offers insight into tax planning considerations and how these have been altered by recent U.S. and global developments. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In today's world, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. The authors' careers span both the academic and private sectors, and they have used their experiences to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts.
