Langer on Practical International Tax Planning: Focus on tax planning
Title | Langer on Practical International Tax Planning: Focus on tax planning PDF eBook |
Author | Denis A. Kleinfeld |
Publisher | Practising Law Inst |
Pages | 1735 |
Release | 2000 |
Genre | Law |
ISBN | 9780872241282 |
Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.
Practical international tax planning
Title | Practical international tax planning PDF eBook |
Author | M.J. Langer |
Publisher | |
Pages | |
Release | 1985 |
Genre | |
ISBN |
Publication surveying all aspects of international tax planning including the effective use of foreign financial centres and tax havens. Subjects deal with are: the legal framework of international tax planning; tax planning in the U.S.A. and outside the U.S.A.; offshore bases outside the U.S.A.; fundamentals of international taxation; import practice. Other subjects are: foreign investment in U.S. real estate and minimizing FIRPTA tax on dispositions of U.S. real estate; offshore banks and trust companies; foreign anti-avoidance measures, etc. The book takes into account the impact of the 1986 Tax Reform Act as well as other changes resulting from new income tax treaties, mutual assistance treaties, and significant changes in the laws of other countries and other revisions.
International Company Taxation and Tax Planning
Title | International Company Taxation and Tax Planning PDF eBook |
Author | Dieter Endres |
Publisher | |
Pages | 0 |
Release | 2015 |
Genre | Corporations |
ISBN | 9789041145567 |
This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.
A Practical Guide to U. S. Taxation of International Transactions
Title | A Practical Guide to U. S. Taxation of International Transactions PDF eBook |
Author | Robert Meldman |
Publisher | Springer |
Pages | 408 |
Release | 1997 |
Genre | Business & Economics |
ISBN |
Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
Contemporary Tax Practice
Title | Contemporary Tax Practice PDF eBook |
Author | John O. Everett |
Publisher | CCH |
Pages | 704 |
Release | 2008 |
Genre | Business & Economics |
ISBN | 9780808018650 |
Contemporary Tax Practice: Research, Planning and Strategies will change the way you teach your tax research course, and the way future professionals learn how to perform tax research. This all new text provides a solid foundation of tax research skills by teaching the nuances of conducting tax research in today's environment. The book then provides exposure to frequently encountered tax planning topics and strategies, better preparing users for their future in tax practice.
Beneficial Ownership in International Tax Law
Title | Beneficial Ownership in International Tax Law PDF eBook |
Author | Angelika Meindl-Ringler |
Publisher | Kluwer Law International B.V. |
Pages | 448 |
Release | 2016-06-07 |
Genre | Law |
ISBN | 9041168397 |
In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
The Netherlands in International Tax Planning
Title | The Netherlands in International Tax Planning PDF eBook |
Author | Johann Müller (podatki) |
Publisher | IBFD |
Pages | 417 |
Release | 2007 |
Genre | Business enterprises, Foreign |
ISBN | 9087220243 |
This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.