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| international taxation course by kpmg: Caterpillar's Offshore Tax Strategy United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations, 2014 |
| international taxation course by kpmg: International White Collar Crime Bruce Zagaris, 2015-08-10 Contemporary transnational criminals take advantage of globalization, trade liberalization, and emerging new technologies to commit a diverse range of crimes. By moving money, goods, services, and people instantaneously they are able to serve purposes of pure economic gain or political violence. This book examines the rise of international economic crime and recent strategies to combat it in the United States and abroad. Focusing on the role of international relations, it draws from case studies in a diverse range of criminality from money laundering to tax evasion. Newly revised and expanded, the second edition of International White Collar Crime incorporates recent developments and updated case studies. New chapters on environmental crimes and securities enforcement under the Dodd–Frank Act continue to make it an essential tool for practicing business, law, and law enforcement. |
| international taxation course by kpmg: Confidence Games Tanina Rostain, Milton C. Regan, Jr., 2014-05-02 The rise and fall of a tax shelter industry that enabled some of America's richest citizens to avoid paying their fair share of taxes. For ten boom-powered years at the turn of the twenty-first century, some of America's most prominent law and accounting firms created and marketed products that enabled the very rich—including newly minted dot-com millionaires—to avoid paying their fair share of taxes by claiming benefits not recognized by law. These abusive domestic tax shelters bore such exotic names as BOSS, BLIPS, and COBRA and were developed by such prestigious firms as KPMG and Ernst & Young. They brought in hundreds of millions of dollars in fees from clients and bilked the U.S. Treasury of billions in revenues before the IRS and Justice Department stepped in with civil penalties and criminal prosecutions. In Confidence Games, Tanina Rostain and Milton Regan describe the rise and fall of the tax shelter industry during this period, offering a riveting account of the most serious episode of professional misconduct in the history of the American bar. Rostain and Regan describe a beleaguered IRS preoccupied by attacks from antitax and antigovernment politicians; heightened competition for professional services; the relaxation of tax practitioner norms against aggressive advice; and the creation of complex financial instruments that made abusive shelters harder to detect. By 2004, the tax shelter boom was over, leaving failed firms, disgraced professionals, and prison sentences in its wake. Rostain and Regan's cautionary tale remains highly relevant today, as lawyers and accountants continue to face intense competitive pressure and regulators still struggle to keep pace with accelerating financial risk and innovation. |
| international taxation course by kpmg: International and Cross-border Taxation in New Zealand Craig Elliffe, 2024 Written by international tax law specialist, Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand’s international tax law and double taxation agreements.The book is designed to provide readers with an understanding of the legal principles and concepts that underpin international tax law and cross-border transactions and practical guidance to assist them to navigate their way through this complex topic [...] International and Cross-Border Taxation in New Zealand is an invaluable resource for lawyers and accountants, as well as an excellent guide for law students studying this area. It provides guidance to practitioners on many of the difficult problems they encounter. Taxpayers, their advisors, and tax administrators need to understand these types of issues. |
| international taxation course by kpmg: U.S. Tax Shelter Industry United States, United States. Congress. Senate. Committee on Governmental Affairs. Permanent Subcommittee on Investigations, 2004 |
| international taxation course by kpmg: IFRS 2 International Accounting Standards Board, 2004 |
| international taxation course by kpmg: International Taxation Handbook Colin Read, Greg N. Gregoriou, 2007-04-13 Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41. |
| international taxation course by kpmg: International Tax Havens Guide , 2002 |
| international taxation course by kpmg: Principles of Taxation in the United States Fabio Ambrosio, 2020-10-04 Taxation is a discipline that does not receive sufficient academic attention. It is typically viewed as a subset of law, accounting, public policy, economics, or finance. In this respect, most academic efforts in the field of taxation are shadowed by a mother discipline. There is currently an unprecedented need to approach tax pedagogy in a way that is independent of another discipline. This book caters to that real and unmet need in tax pedagogy. One of the book’s advantages is that it is not tied to a specific tax year and does not coddle the reader with volumes of time-sensitive information. In this book the tax year is never the focus, as the center stage is reserved for teaching the principles and skills necessary to independently find answers. The reader will learn to appreciate the complexity of the American tax system and will be endowed with the contextual understanding necessary to formulate educated opinions about how taxes work and, most importantly, why. Contrary to common belief, taxation in the United States has remained fairly stable for the last 100 years. This book uses the federal individual income tax as a vehicle to unveil the mechanics that make up the American tax system. This book is essential reading for students taking a first course in taxation, at the undergraduate or graduate level, as part of programs in accounting, law, public administration, or business at large. |
| international taxation course by kpmg: Taxation of Crypto Assets Niklas Schmidt, Jack Bernstein, Stefan Richter, Lisa Zarlenga, 2020-11-27 The emergence of crypto assets has required taxation authorities worldwide to develop unprecedented policies and compelled tax lawyers to apply existing laws in new ways. This book – the only one to focus solely on the taxation of crypto assets – provides a detailed country-by-country analysis of how the tax law of thirty-nine countries may apply to this rapidly developing area, including different use cases and compliance and documentation requirements. Following an overview of the technology and key characteristics of crypto assets, as well as the key tax concepts and types of taxes that could apply to them, leading practitioners in each particular jurisdiction summarize the relevant tax law in that country. Fully explained are such aspects of crypto assets as the following and how they are interrelated: sales; exchanges; receipt as remuneration; forks; airdrops; mining; staking; initial coin offerings; security token offerings; and initial exchange offerings. Contributors describe how each jurisdiction applies income and capital gains taxation, value-added tax and sales tax, withholding taxes, transfer taxes, and gift, inheritance, estate and wealth taxes in the context of crypto assets. Reporting requirements and enforcement are also covered. Tax law, as it applies to crypto assets, is new and continues to evolve. This book will be welcomed as the premier resource for tax practitioners, government officials, advisors, investors, issuers, users of crypto assets, and taxation academics who are seeking informed awareness of the policy choices countries make in dealing with the taxation of this new technology. Tax lawyers dealing with crypto assets will have comprehensive practical guidance on how to comply with the tax laws of multiple jurisdictions. |
| international taxation course by kpmg: To Cook a Continent Nnimmo Bassey, 2012 Arguing that the climate crisis confronting the world today is rooted mainly in the wealthy economies’ abuse of fossil fuels, indigenous forests, and global commercial agriculture, this important book investigates how Africa has been exploited and how Africans should respond for the good of all. As it examines the oil industry in Africa and probes the causes of global warming, this record warns of its insidious impacts and explores false solutions. Demonstrating that the issues around natural resource exploitation, corporate profiteering, and climate change must be considered together if the planet is to be saved, the book suggests how Africa can overcome the crises of environment and global warming. |
| international taxation course by kpmg: Tax Notes International , 2007 |
| international taxation course by kpmg: Customs Law of the European Union Massimo Fabio, 2020-03-12 Today, global competition obliges companies dealing in international trade to modernize their procedures of delivery in order to minimize the customs burden and simplify the relation with customs authorities. Customs planning is the current option to be effective in the worldwide marketplace. However, customs officials are facing new challenges: they must ensure the smooth flow of trade while applying necessary controls on the one hand, while protecting the health and safety of the Community's citizens on the other. To achieve and maintain the correct balance between these demands, control methods are constantly evolving raising major challenges to those charged with planning and compliance. This book is a highly practical work dealing with the ins and outs of European Union (EU) customs law. Cases of study, jurisprudence and comparative law support the analysis of the different legal tools. The consolidated principles ruling the transactions within WTO Member States applied in EU law offer the readers the opportunity to understand how customs rules can be applied in any customs jurisdiction. Authored by an international tax lawyer with extensive experience enforcing EU customs law as a former member of Italy’s financial police, this handy resource is designed to help the reader stay in compliance with the laws controlling EU importing and exporting while structuring transactions in a business-friendly manner. |
| international taxation course by kpmg: Taxation Without Representation Michael Littlewood, 2010-01-01 This book tells an instructive tale of Hong Kong's tax system from 1940 (when taxes on income were first introduced in the territory) until the present day. For Hong Kong's own historians and political scientists, it supplies cogent but previously neglected evidence of the influence of the territory's business interests. For students of British imperialism, it provides a compelling case-study of relations between London and a recalcitrant colony. For Hong Kong's own tax profession, it corrects the notion that the territory's tax system was the product of governmental design. And for tax theorists and taxpayers everywhere, it suggests how it might be possible to structure a combination of very light taxes and very low public spending so as to win broad popular support.--Michael Littlewood is a member of the Faculty of Law at the University of Auckland, where he teaches tax. His work has been published in the U.S., the U.K., Hong Kong, China, the Netherlands, Australia and New Zealand. He lived in Hong Kong from 1989 until 2003.--An excellent read ... partly a matter of 'who done it?' but, even more so, of 'how did they get away with it?' Dr. Littlewood's book will prove indispensable for anyone wanting to use the Hong Kong precedent to argue for a flat rate tax system in their own country. - John Tiley, Professor of Tax Law, University of Cambridge--Fascinating ... [This book is] a first-rate history and raises troubling questions about the necessity of linking taxes and democratic choice. The book also raises intriguing doubts about whether low taxes and low services may be an acceptable alternative model to the prevalent high-tax, high-services Western welfare state. This book should be required reading for students of political science, history, sociology and law. - Reuven Avi-Yonah, Irwin I. Kohn Professor of Law, University of Michigan----- |
| international taxation course by kpmg: U.S. Tax Shelter Industry: The Role of Accountants, Lawyers, and Financial Professionals, S. Hrg. 108-473, Vol. 1 of 4, November 18 and 20, 2003, 108-1 Hearings, *. , 2004 |
| international taxation course by kpmg: Capital Gains Taxation Michael Littlewood, Craig Elliffe, 2017-08-25 Capital gains taxes pose a host of technical and political design problems and yet, while the literature on the theory of capital gains taxation is substantial, little has been published on how governments have addressed these dilemmas. Written by a team of distinguished international experts, Capital Gains Taxation addresses the gap in the literature; it explains how a number of countries tax capital gains and the successes and pitfalls of these methods. |
| international taxation course by kpmg: Accounting and Valuation Guide AICPA, 2019-09-16 Developed for preparers of financial statements, independent auditors, and valuation specialists, this guide provides nonauthoritative guidance and illustrations regarding the accounting for and valuation of portfolio company investments held by investment companies within the scope of FASB ASC 946, Financial Services —Investment Companies, (including private equity funds, venture capital funds, hedge funds, and business development companies). It features16 case studies that can be used to reason through real situations faced by investment fund managers, valuation specialists and auditors, this guide addresses many accounting and valuation issues that have emerged over time to assist investment companies in addressing the challenges in estimating fair value of these investments, such as: Unit of account Transaction costs Calibration The impact of control and marketability Backtesting |
| international taxation course by kpmg: Tax Risk Management Anuschka Bakker, Sander Kloosterhof, 2010 In response to a number of large corporate failures, risk management has recently become a major consideration for most organizations. At the same time, taxation has been recognized as an area having its own unique risk profiles. This book provides a practical guide for those working in today's ever-changing corporate environment. It contains an introduction to tax risk management and discussions on the tax control framework that allow corporate tax departments to identify and manage companies' tax-related risks. The book also includes country chapters, which provide practical examples of the development and application of tax control frameworks. |
| international taxation course by kpmg: Taxation International , 1990 |
| international taxation course by kpmg: Tax Haven Banks and U.S. Tax Compliance United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations, 2009 |
| international taxation course by kpmg: Transfer Pricing and Financing Raffaele Petruzzi, Michael Lang, 2023-03-09 In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation. |
| international taxation course by kpmg: Advanced Issues in International and European Tax Law Christiana HJI Panayi, 2015-12-03 This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world. |
| international taxation course by kpmg: OECD Arbitration in Tax Treaty Law Alicja Majdanska, Laura Turcan, 2018-09-14 Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes. |
| international taxation course by kpmg: Interpretation and Application of Tax Treaties in North America Juan Angel Becerra, 2007 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. |
| international taxation course by kpmg: When Good Companies Go Bad Donald W. Beachler, Thomas Shevory, 2014-09-09 Covering the entire world of business from heavy industry to the financial houses of Wall Street, this book shines a spotlight on 100 of the most infamous cases of misconduct and malfeasance in corporate history. Corporations are in the business of making money. But when companies forget ethics, take operational shortcuts, or willingly endanger customers and the general public in their quest for profits, disasters of enormous magnitude can result. This book examines 100 of the worst cases of corporate greed and irresponsibility and poses the questions: Is it necessary or desirable to conduct business in this manner? Do the penalties and other punishments levied against these companies go far enough? And what is the government's responsibility for keeping corporate misdeeds in check? Coauthored by distinguished public policy experts, When Good Companies Go Bad: 100 Corporate Miscalculations and Misdeeds presents a representative sample of cases on a variety of topics, such as the financial sector, health care, environmental protection, product liability, and copyright. This broad introduction to the dark side of the corporate world focuses on events and scandals that resulted in substantial financial penalties, regulatory actions, or criminal convictions. The cases are presented in a readable and engaging format, making the book an illuminating and informative read for high school and college students as well as businesspeople, lawyers, journalists, and professors who teach American politics, public law, or public policy. |
| international taxation course by kpmg: Resolutions Book International Fiscal Association, 1988 |
| international taxation course by kpmg: Concept and Implementation of CFC Legislation Nathalie Bravo, Alexandra Miladinovic, 2021-09-21 An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens. |
| international taxation course by kpmg: Tax Morale What Drives People and Businesses to Pay Tax? OECD, 2019-09-11 Unlocking what drives tax morale – the intrinsic willingness to pay tax – can greatly assist governments in the design of tax policies and their administration, particularly in developing countries where compliance rates are low. This report builds on previous OECD research to identify some of the key socio-economic and institutional drivers of tax morale across developing countries, and seeks to test for evidence of the social contract by examining the impact of public services on tax morale. It also uses new data on tax certainty as an entry point to explore tax morale in businesses, where existing research is very limited. Finally, the report identifies a range of factors related to the tax system that may affect business decision making, how they vary across regions, and suggests some areas for future research. Overall, the report provides a range of suggestions for further work, and how tax morale considerations can be integrated into holistic tax compliance strategies. |
| international taxation course by kpmg: Intercompany Agreements for Transfer Pricing Compliance Paul Sutton, 2019-03-11 This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups. |
| international taxation course by kpmg: Platforms in EU VAT Law Christina Pollak, 2022-10-18 Applying the provisions of the European Union Value Added Tax (EU VAT) Directive poses challenges when applied to the digital platform economy. Recent responses to these challenges revolve around the deemed supplier regime introduced by the so-called e-commerce package, and this regime is thus the focus of this indispensable work, the first to provide an in-depth analysis of the regime, its background and scope, its interpretation, and its application in practice. In its detailed examination of how digital platforms that enable supplies of goods through their interfaces are treated for VAT purposes under EU law, the author elucidates such topics and issues as the following: The qualification of the sale of goods through platforms; supply of the platform service to the underlying supplier; supply of the platform service to the customer; supply of goods from the underlying supplier to the customer; supplies from third countries; the Organisation for Economic Co-operation and Development (OECD) proposal’s influence on the interpretation of the EU e-commerce package; chain transactions; determination of the place of supply; chargeable event and chargeability of VAT; taxable amount; applicable rates and exemptions; platform’s recordkeeping obligations; accompanying customs measures; return of goods and warranty cases; and future of effective and efficient VAT collection. The author also undertakes a detailed analysis of a potential infringement of the principle of equality, neutrality, and the right to conduct a business. Fully taking into consideration the case law of the CJEU, administrative practice, and the relevant academic literature, the author’s research reveals the weaknesses, opportunities, and limits for Member States’ implementation of EU VAT law. The upshot is an important work that promises to make the EU VAT system more fraud-resistant, simplify compliance obligations, enforce the principle of neutrality, and reduce distortion of competition. The book will be of immeasurable value to any practitioner and policymaker approaching any case involving the deemed supplier regime for digital platforms with full awareness of the applicable rules. |
| international taxation course by kpmg: Creative Tax Planning for Real Estate Transactions , 2010 |
| international taxation course by kpmg: The Tax Management International Forum , 2002 |
| international taxation course by kpmg: International Tax Administration Jonathan Mendel, 2010 The biennial tax administration conference held by ATAX ... ninth conference was held in Sydney in April 2010 ... . This edited volume of papers from the conference is organized into the three key themes of the conference ...--Back cover. |
| international taxation course by kpmg: Interpretation and Application of Tax Treaties Ned Shelton, 2011-12-31 This new edition provides a fully updated, 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. Written by an expert in the field and taking the practical approach rather that the academic, this truly is an essential global tool for the tax adviser. |
| international taxation course by kpmg: Tax simplification - An African Perspective Edited by Chris Evans, Riël Franzsen, Elizabeth (Lilla) Stack 2019 Edited by Chris Evans, Riël Franzsen, Elizabeth (Lilla) Stack, 2019-01-01 Tax simplification - An African Perspective Edited by Chris Evans, Riël Franzsen, Elizabeth (Lilla) Stack 2019 ISBN: 978-1-920538-96-5 Pages: 347 Print version: Available Electronic version: Free PDF available About the publication Why are tax systems so complex and what are the causes and consequences of such complexity? The simplification of tax systems is one of the most important issues faced today in worldwide efforts to modernise and strengthen government finance and revenue raising capacities. Nowhere is it more important than throughout the rapidly emerging economies of the dynamic African region. This volume brings together contributions in this field from a conference held in South Africa in October 2018 and provides a unique synthesis of knowledge and understanding gained from the specialist expertise and diverse backgrounds brought to the tax simplification debate by those authors. Featured topics include: Taxpayers’ rights to simplicity The African experience of tax simplification Simplification trends among small and medium sized entities Pension tax simplification Sources of complexity in value added taxation Simplification of recurrent property taxes Complexity and approaches to international taxation Complexity and taxation of multinational enterprises Lessons from overseas. The analysis of these topics includes timely and relevant perspectives from the experience in other jurisdictions including Australia, Canada, New Zealand, the United Kingdom and the United States. The volume will be an essential reference for researchers and others interested in the field from academia, government, legal and accounting practice and public policy organisations in African and other countries worldwide.Table of Contents Preface Foreword – Tax Simplification in the United Kingdom: Some Personal Reflections John Whiting Contributors Introduction Elizabeth (Lilla) Stack, Chris Evans and Riël Franzsen Tax Complexity and Tax Simplification: A Critical Review of Concepts and Issues Binh Tran-Nam, Annet Wanyana Oguttu and Kyle Mandy The Taxpayers’ Right to Tax Simplicity in South Africa and the United States Carika Fritz and Nina E Olson The Role of the Office of Tax Simplification in the United Kingdom and Lessons for Other Countries Yige Zu and Lynne Oats An Analysis of the Tax Simplification Initiatives for Pension Provision in the United Kingdom and South Africa Bernadene de Clercq, Andy Lymer and Chris Axelson Simplification Lessons from New Zealand Adrian Sawyer, Marina Bornman and Greg Smith Legal Uncertainty in the South African VAT Marius van Oordt and Richard Krever Simplifying Recurrent Property Taxes in Africa Riël Franzsen, Abdallah Ali-Nakyea and Adams Tommy Statutory and Effective Complexity for Individual Taxpayers in South Africa Sharon Smulders, Karen Stark and Deborah Tickle Small and Micro Businesses: Case Studies on the Complexity of ‘Simplified’ Schemes Heinrich Dixon, Judith Freedman and Wollela Abehodie Yesegat Tax Complexity for Multinational Corporations in South Africa – Evidence from a Global Survey Thomas Hoppe, Reyhaneh Safaei, Amanda Singleton and Caren Sureth-Sloane International Tax Simplification in South Africa through Managing Substantive Complexity and Improving Drafting Efficiency Jinyan Li and Teresa Pidduck Bibliography Index |
| international taxation course by kpmg: Tax Planning with Holding Companies - Repatriation of US Profits from Europe Rolf Eicke, 2009-01-01 The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries. |
| international taxation course by kpmg: SEC Docket United States. Securities and Exchange Commission, 2001 |
| international taxation course by kpmg: Transfer Pricing and Dispute Resolution Anuschka Bakker, Marc M. Levey, 2011 This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices. |
| international taxation course by kpmg: Tolley's International Taxation of Corporate Finance John Abrahamson, 2014-08-01 This book introduces and discusses international tax issues relating to corporate finance, group treasury, and banking operations. The book is intended to benefit accountants, lawyers, economists, financial managers and government officials by explaining practical corporate finance international tax issues. These issues include: examples of country tax regimes; corporate finance including issuing shares; debt instruments; bank loans; investment banking activities; and alternative finance such as crowdfunding; microfinance and alternative energy funding; and international tax issues relating to interest and dividend flows; capital gains; and foreign tax credits. The book reviews related topics, including: mergers and acquisitions funding; asset and project finance; securitisation; derivatives; hybrid securities and entities; Islamic financing; bank capital structures; group treasury companies; debt restructuring; and transfer pricing issues. The book is based on Corporate Finance and International Taxation courses presented by the author in London, Paris, Zurich, Lugano, Rio de Janeiro, Mexico City, Hong Kong and Singapore. |
| international taxation course by kpmg: Federal Securities Law Reporter , 1941 |
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No importa el camino o el tipo de trabajo, el camión ligero CT4 de International® es el camión de 3 y 4 toneladas de mayor utilidad.
Camiones Eléctricos | International®
Descubre los camiones eléctricos International®, diseñados para un futuro más sustentable con cero emisiones. Eficiencia e innovación.
