Legislative History of United States Tax Conventions
Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
Published: 1962
Total Pages: 1532
ISBN-13:
DOWNLOAD EBOOK →Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
Published: 1962
Total Pages: 1532
ISBN-13:
DOWNLOAD EBOOK →Author: United States. Internal Revenue Service
Publisher:
Published: 1980
Total Pages: 12
ISBN-13:
DOWNLOAD EBOOK →Author: Kevin Holmes
Publisher: IBFD
Published: 2007
Total Pages: 433
ISBN-13: 9087220235
DOWNLOAD EBOOK →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: Jon E. Bischel
Publisher:
Published: 1978
Total Pages: 1002
ISBN-13:
DOWNLOAD EBOOK →Compilation of studies in the field of international taxation in United States bilateral tax treaties with other countries (the United Kingdom, France, Germany and Japan) as well as a description of structure and operation of tax treaties in general.
Author: Arvid Aage Skaar
Publisher: Kluwer Law International B.V.
Published: 2020-06-19
Total Pages: 957
ISBN-13: 9403520647
DOWNLOAD EBOOK →A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Author: Richard L. Doernberg
Publisher:
Published: 1999
Total Pages: 444
ISBN-13:
DOWNLOAD EBOOK →Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Author: Sunita Jogarajan
Publisher: Cambridge University Press
Published: 2018-05-10
Total Pages: 425
ISBN-13: 1108381820
DOWNLOAD EBOOK →Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Author: United States
Publisher: Springer
Published: 1991-02-05
Total Pages: 678
ISBN-13:
DOWNLOAD EBOOK →This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Author: Karl P Sauvant
Publisher: Oxford University Press
Published: 2009-03-27
Total Pages: 800
ISBN-13: 0199745188
DOWNLOAD EBOOK →Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Author: United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight
Publisher:
Published: 1980
Total Pages: 170
ISBN-13:
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