Interpretation And Application Of Tax Treaties In North America

Author : Juan Angel Becerra
Publisher : IBFD
Page : 299 pages
File Size : 41,7 Mb
Release : 2007
Category : Canada
ISBN : 9789087220198

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Interpretation and Application of Tax Treaties in North America by Juan Angel Becerra Pdf

This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Author : Fraser Milner Casgrain (Firm)
Publisher : CCH Canadian Limited
Page : 612 pages
File Size : 49,7 Mb
Release : 2009
Category : Business & Economics
ISBN : 1554960029

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Canada-U.S. Tax Treaty by Fraser Milner Casgrain (Firm) Pdf

Author : Anonim
Publisher : Unknown
Page : 58 pages
File Size : 49,9 Mb
Release : 1981
Category : Double taxation
ISBN : STANFORD:36105110745176

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Explanation of Proposed Income Tax Treaty Between the United States and Canada by Anonim Pdf

Author : United States. Congress. Joint Committee on Taxation
Publisher : Unknown
Page : 68 pages
File Size : 54,7 Mb
Release : 1984
Category : Double taxation
ISBN : STANFORD:36105110745887

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Explanation of proposed income tax treaty (and proposed protocol) between the United States and Canada by United States. Congress. Joint Committee on Taxation Pdf

Author : Ned Shelton
Publisher : Bloomsbury Professional
Page : 662 pages
File Size : 53,8 Mb
Release : 2004-01-01
Category : Business & Economics
ISBN : 1845923413

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Interpretation and Application of Tax Treaties by Ned Shelton Pdf

"This book provides an excellent, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Other highlights include case studies and OECD model treaties. Written by an expert in the field and taking the practical approach rather than the academic, this truly is an essential global tool for the tax adviser wishing to use tax treaties in tax planning."

Author : United States. Congress. Senate. Committee on Foreign Relations
Publisher : Unknown
Page : 60 pages
File Size : 51,8 Mb
Release : 1995
Category : Business & Economics
ISBN : STANFORD:36105110745879

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Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and Canada by United States. Congress. Senate. Committee on Foreign Relations Pdf

Author : Jeffrey A. Schoenblum,Tax Management Inc,Bloomberg BNA.
Publisher : Unknown
Page : 128 pages
File Size : 52,9 Mb
Release : 2024-05-10
Category : Decedents' estates
ISBN : 1558719784

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United States Estate and Gift Tax Treaties by Jeffrey A. Schoenblum,Tax Management Inc,Bloomberg BNA. Pdf

... describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties to which the United States is a party, as well as the income tax treaty with Canada, which bears on U.S. transfer taxes as well as Canadian income tax at death. The portfolio is divided into six parts. Part I: Introduction, explains the purpose and types of transfer tax treaties. Part II: Situs-Type Treaties, describes when situs-type transfer tax treaties apply and explains how a situs-type treaty assigns primary taxing jurisdiction to one country. It also analyzes the effect that situs-type treaties have on the deductions and credits of treaty countries. Part III: Domicile-Type Treaties, describes when domicile-type treaties apply and how these treaties assign primary taxing jurisdiction. It also analyzes the situs rules that are incorporated into domicile-type treaties, the effect that domicile-type treaties have on the deductions, exemptions, and credits of treaty countries, and the general operation of the treaties' nondiscrimination provisions. Part IV: Special, Administrative, and Enforcement Provisions, discusses the ways in which transfer tax treaties enable a treaty country to enforce the collection of death taxes and exchange information with the other country, as well as issues that a taxpayer subject to a treaty may face in reporting income. Part V: Treaty Interpretation, sets forth the principles of treaty interpretation and construction. Part VI: Particular Treaty Analysis, discusses the details of each transfer tax treaty.

Author : Jesse S Brodlieb
Publisher : Unknown
Page : 644 pages
File Size : 55,5 Mb
Release : 2015
Category : Double taxation
ISBN : 1554968542

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Canada-U.S. Tax Treaty by Jesse S Brodlieb Pdf

Wolters Kluwer?s Canada-U.S. Tax Treaty: A Practical Interpretation contains the full text of the Canada - U.S. Tax Convention, as amended by the First through Fifth Protocols, with updated commentary by Dentons following each Article of the Treaty. The Technical Explanations of the Treaty and the Third, Fourth, and Fifth Protocols, as provided by the U.S. Treasury Department, are reproduced, along with a report on the Fifth Protocol by the Joint Committee on Taxation for the U.S. Senate.

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 46,9 Mb
Release : 1981
Category : Capital gains tax
ISBN : STANFORD:36105043817480

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Canada-U.S. Tax Treaty by Anonim Pdf

Author : Canada
Publisher : Don Mills, Ont. : CCH Canadian
Page : 100 pages
File Size : 45,9 Mb
Release : 1984
Category : Double taxation
ISBN : NYPL:33433065158648

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The New Canada-U.S. Tax Treaty with Technical Explanation by Canada Pdf

Author : American Law Institute
Publisher : Unknown
Page : 384 pages
File Size : 43,5 Mb
Release : 1992
Category : Aliens
ISBN : STANFORD:36105044583636

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Federal Income Tax Project by American Law Institute Pdf

Proposals on United States income tax treaties. The book is a companion volume to "International aspects of United States income taxation" published in 1987. While the 1987 volume addressed various aspects of US internal income tax law as applied to international transactions, this volume deals with the special set of problems involved in treaties between the US and their trading partners by which it is sought to bring divergent national tax laws and incidents of taxation into reasonable accord.

Author : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 49,9 Mb
Release : 2007
Category : Double taxation
ISBN : 9789087220235

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International Tax Policy and Double Tax Treaties by Kevin Holmes Pdf

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Author : OECD
Publisher : OECD Publishing
Page : 92 pages
File Size : 40,8 Mb
Release : 2011-08-03
Category : Electronic
ISBN : 9789264119222

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Corporate Loss Utilisation through Aggressive Tax Planning by OECD Pdf

After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

Author : Jonathan Schwarz
Publisher : Kluwer Law International B.V.
Page : 870 pages
File Size : 50,5 Mb
Release : 2021-09-28
Category : Law
ISBN : 9789403526317

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Schwarz on Tax Treaties by Jonathan Schwarz Pdf

Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 42,7 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827

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U.S. Tax Guide for Aliens by Anonim Pdf