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| principle of taxation law: Principles of Canadian Income Tax Law Jinyan Li, Joanne E. Magee, J. Scott Wilkie, 2017 |
| principle of taxation law: Transfer Pricing and the Arm's Length Principle in International Tax Law Jens Wittendorff, 2010-01-01 The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy. |
| principle of taxation law: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle Eva Escribano, 2019-05-10 Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world. |
| principle of taxation law: 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. |
| principle of taxation law: Exploring the Nexus Doctrine In International Tax Law Ajit Kumar Singh, 2021-05-14 In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine. |
| principle of taxation law: The Principle of Equality in European Taxation Gerard Meussen, 1999-10-12 Or her tax trial |
| principle of taxation law: Politics, Taxation, and the Rule of Law Donald P. Racheter, Richard E. Wagner, 2012-12-06 Public Interest Institute began operations in 1992 as Iowa's only state-level, independent, research organization. As a public-policy research organization, our four principal goals are to become an information and analysis resource for all Iowans; provide local, state, and national policy-makers with a rigorous, objective, and understandable analysis of specific policy initiatives; identify practical alternatives for action on critical issues; and provide a forum for policy-makers and individuals to share ideas and concerns. The Institute promotes the importance of a free-enterprise economic system and its relationship to a free and democratic society. It seeks to support the proper role of a limited government in a society based upon individual freedom and liberty. Concerned citizens are challenged to become better informed about public issues, for ideas have consequences, and involved individuals can make a difference. Following the general treatment of how to achieve these ideals contained in LIMITING LEVIATHAN, we have continued our series of books designed to examine the topics raised there in greater depth. In FEDERALIST GOVERNMENT IN PRINCIPLE AND PRACTICE we developed the ways in which dividing governmental power between levels such as national and state can help citizens preserve their freedoms. In this volume we develop the ways in which property rights do the same. |
| principle of taxation law: Principles of International Taxation Lynne Oats, 2021-09-30 The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition. |
| principle of taxation law: Davies Principles of Tax Law Geoffrey Morse, Sandra Eden, F. R. Davies, 2020 |
| principle of taxation law: Permanent Establishment Arvid Aage Skaar, 2020-06-19 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. |
| principle of taxation law: A Multilateral Convention for Tax Sergio André Rocha, Allison Christians, 2021-11-29 The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels. |
| principle of taxation law: Fundamentals of Taxation Pasquale Pistone, 2019 |
| principle of taxation law: Principles of Taxation Law 2018 Kerrie Sadiq, Cynthia Coleman, Rami Hanegbi, Sunita Jogarajan, Richard Krever, Wes Obst, Jonathan Teoh, Antony KF Ting, 2017-07-12 Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2018 brings much needed clarity to this area of law. Utilising many methods to make this often daunting subject achievable, particular features of the 2018 edition include: seven parts: overview and structure, principles of income, deductions and offsets, timing issues, investment and business entities, tax avoidance and administration, and indirect taxes; clearly structured chapters within those parts grouped under helpful headings; flowcharts, diagrams and tables, end of chapter practice questions, and case summaries; an appendix containing all of the up to date and relevant rates; and the online self-testing component mentor, which provides questions for students of both business and law; Every major aspect of the Australian tax system is covered, with chapters on topics such as goods and services tax, superannuation, offsets, partnerships, capital gains tax, trusts, company tax, tax administration and state taxes. All chapters have been thoroughly revised. Principles of Taxation Law 2018 is the perfect tool to guide the reader from their initial exposure to the subject to success in taxation law exams. |
| principle of taxation law: The Theory and Practice of Modern Taxation William Raymond Green, 1938 |
| principle of taxation law: State Tax Policy David Brunori, 2005 |
| principle of taxation law: Critical Tax Theory Bridget J. Crawford, 2009-06-22 Tax law is political. This book highlights and explains the major themes and methodologies of a group of scholars who challenge the traditional claim that tax law is neutral and unbiased. The contributors to this volume include pioneers in the field of critical tax theory, as well as key thinkers who have sustained and expanded the investigation into why the tax laws are the way they are and what impacts tax laws have on historically disempowered groups. This volume, assembled by two law professors who work in the field, is an accessible introduction to this new and growing body of scholarship. It is a resource not only for scholars and students in the fields of taxation and economics, but also for those who engage with critical race theory, feminist legal theory, queer theory, class-based analysis, and social justice generally. Tax is the one area of law that affects everyone in our society, and this book is crucial to understanding its impact. |
| principle of taxation law: Principles of Business Taxation Janet Grange, Geralyn A. Jover-Ledesma, Gary L. Maydew, 2013-03 The CCH Principles of Business Taxation course approaches the study of taxation from the perspective of the student who will become a business person faced with business decisions that are inevitably affected by tax considerations. This perspective leads to a very different coverage in this textbook -- coverage that is useful for accounting, finance and general business majors. The new edition focuses on the central concepts that build our tax framework and avoids small exceptions and details to ensure that the student can confidently master the critical underpinnings of federal taxation. It abandons minutia that not only affects a very small number of taxpayers, but also tends to change often. In this way, there are no wasted motions and students gain a stronger, more solid understanding of federal tax principles. |
| principle of taxation law: Federal Income Taxation Michael J. Graetz, 2004 |
| principle of taxation law: Philosophical Foundations of Tax Law Monica Bhandari, 2017 This collection brings together major themes and difficult questions in the philosophical foundations of tax law. It allows the reader to consider how tax systems should move forward in the modern world, with a sound philosophical basis, to provide the practical tax system that the state requires and citizens deserve. |
| principle of taxation law: Principles & Practice of Taxation Mohammed Amidu, 2019 |
| principle of taxation law: International Taxation of Trust Income Mark Brabazon, 2019-05-02 This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students. |
| principle of taxation law: Beneficial Ownership in International Tax Law Angelika Meindl-Ringler, 2016 Series on International Taxation Volume 58 Beneficial Ownership in International Tax Law compares the use and interpretation of beneficial ownership, both current and historical, in a wide range of national jurisdictions and the EU. 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 is a book dedicated to establishing how beneficial ownership should ideally be interpreted ultimately shedding a clearer light than has heretofore been available on the meaning of the term. What's in this book: The author on thorough analysis of the application of beneficial ownership touches on the following aspects: 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 princip≤ attribution-of-income rules; and the role of agents, nominees and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in the context of a domestic law and treaty in numerous jurisdictions - with particular emphasis on the United Kingdom, Australia, the United States and Germany - is a major feature of the presentation. Furthermore, a comprehensive coverage of how the concept of beneficial ownership has developed over the past half-century is discussed. How this will help you: This book provides thorough guidance in 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 helps in developing a logical, easy-to-apply practical approach to beneficial ownership. Highlights of complex issues and important jurisdictional differences in the interpretation of beneficial ownership ensure an in-depth understanding of the concept of beneficial ownership, which serves to be of immeasurable value to lawyers, tax authorities, policymakers and other professionals working with taxable international transactions of any kind. |
| principle of taxation law: Research Handbook on European Union Taxation Law Christiana HJI Panayi, Werner Haslehner, Edoardo Traversa, 2020-01-31 Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research. |
| principle of taxation law: Introduction to the Law of Double Taxation Conventions Michael Lang, 2021-04-01 The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts. |
| principle of taxation law: Introduction to Taxation William D. Popkin, 2008 |
| principle of taxation law: The Cambridge Rawls Lexicon Jon Mandle, David A. Reidy, 2014-12-11 John Rawls is widely regarded as one of the most influential philosophers of the twentieth century, and his work has permanently shaped the nature and terms of moral and political philosophy, deploying a robust and specialized vocabulary that reaches beyond philosophy to political science, economics, sociology, and law. This volume is a complete and accessible guide to Rawls' vocabulary, with over 200 alphabetical encyclopaedic entries written by the world's leading Rawls scholars. From 'basic structure' to 'burdened society', from 'Sidgwick' to 'strains of commitment', and from 'Nash point' to 'natural duties', the volume covers the entirety of Rawls' central ideas and terminology, with illuminating detail and careful cross-referencing. It will be an essential resource for students and scholars of Rawls, as well as for other readers in political philosophy, ethics, political science, sociology, international relations and law. |
| principle of taxation law: Taxation in European Union Pietro Boria, 2017-05-04 This book provides a comprehensive and systematic overview of the main topics of taxation in European law. The sequence of arguments follows an institutional logic, respecting the academic tradition of tax law. It first outlines the general framework of EU institutions, with a particular focus on the set of regulations regarding taxation with reference to the stage of formation of EU rules and the potential contrast with national legal systems. It then explores the general principles emerging from the European treaties that typically involve the taxation system, and examines in detail the fiscal importance of European freedoms, the principle of tax non-discrimination, the balance between national interest and EU values, tax harmonization, state aids and other general principles applicable in tax jurisdiction. Lastly, it offers an overall assessment of the development of the European integration process, with particular regard to the nexus between taxation power and sovereignty, in order to highlight the possible and desirable next stages of the evolution of “European tax law”. |
| principle of taxation law: Taxation and Democracy Sven Steinmo, 1993-01-01 Examining the structure, politics and historic development of taxation in several countries, this book compares three quite different political democracies. It provides an account of the ways these democracies have financed their welfare programs despite w |
| principle of taxation law: Federal Limitations on State and Local Taxation Paul James Hartman, 1981 |
| principle of taxation law: The Fundamentals of Canadian Income Tax Vern Krishna, 1986-01-01 |
| principle of taxation law: State and Local Taxation Charles W. Swenson, John E. Karayan, Sanjay Gupta, Joseph W. Neff, 2020 In recent years, stunning advances in telecommunications, capital mobility, and distribution channels have not only greatly increased the number of transactions and ventures subject to multiple taxation, but also have made it easier to plan around such taxes. Tax and legal professionals, entrepreneurs, and business managers must have a fundamental understanding of the state and local tax implications of key transactions. State and Local Taxation: Principles and Planning, Third Edition covers the important tax issues of today's global business environment. |
| principle of taxation law: Principles of Taxation for Business and Investment Planning 2020 Edition Shelley C. Rhoades-Catanach, Sally Jones, Sandra R. Callaghan, 2019-04-08 FULLY UPDATED FOR 2019 TAX LAW Principles of Taxation for Business and Investment Planning focuses on the role taxes play in business and investment decision, presenting the general roles of taxation and discussing its implications for all tax-paying entities before delving into a specific exception. The benefit of this approach is a strong grasp of the fundamental principles informing taxation rules: students comprehend the framework of the tax system, making future changes to the tax code easier to understand-no matter how many there are. Unlike traditional introductory titles, Principles of Taxation for Business and Investment Planning downplays the technical detail that makes the study of Taxation convoluted and off-putting for business students. This title shows students that an understanding of Taxation is not only relevant, but critical to their success in the business world. Don't just teach your students the tax code; teach them how the tax code affects business decision making with the 2020 edition! |
| principle of taxation law: International Business Taxation Sol Picciotto, 1992-03-02 This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws. |
| principle of taxation law: Understanding Corporate Taxation Leandra Lederman, Emily Cauble, 2025 This clearly written treatise is designed to make the complex subject of corporate taxation very accessible. It uses straightforward language, charts, checklists, diagrams, and numerous examples to aid readers' comprehension and retention of the material. Understanding Corporate Taxation also includes discussion of relevant cases. It is designed to supplement any corporate tax casebook or to be used on its own. This fifth edition is fully updated for the Inflation Reduction Act of 2022's excise tax on stock buybacks and the new corporate alternative minimum tax (the CAMT) contained in the Act. This edition also contains additional diagrams. The book starts with an introductory chapter that discusses the choice of business form; details the idea that corporate profits generally are subject to double taxation (once at the corporate level and again at the shareholder level); introduces the Qualified Business Income deduction; and discusses the basics of anti-abuse rules, such as the step-transaction doctrine. Those anti-abuse rules are explored in more detail in a later chapter, as are proposals to partially or fully eliminate double taxation. In addition, a chapter addresses the taxation of S corporations, which are taxed under a single-tax paradigm. That chapter also discusses the Qualified Business Income deduction, including numerous examples. Similar to most corporate tax casebooks, the bulk of the book is organized using a cradle-to-grave approach that traces the life cycle of a corporation, beginning with formation and capitalization and ending with liquidation of the corporation. Between those chapters, the book discusses operational issues, including the capital structure of a corporation, distributions of cash or property, stock redemptions, and stock dividends. After corporate liquidations, the book explores more advanced topics, such as taxable stock or asset acquisitions; non-taxable corporate reorganizations and divisions; the carryover of tax attributes (such as net operating losses) following certain non-recognition transactions; and the treatment of corporate tax shelters. Throughout, the book uses specific examples, diagrams of transactions, summary charts, and checklists to clarify and distill key points. |
| principle of taxation law: Introduction to Austrian Tax Law Kurt Ubelhoer, Sebastian Pfeiffer, Eline Huisman, Erich Schaffer, 2014-12-10 |
| principle of taxation law: Tax Policy Handbook Mr. Parthasrathi Shome, 1995-04-25 Edited by Parthasarathi Shome, this Handbook was written primarily for economists who are responsible for analyzing and evaluating economic policies of developing countries at an applied level, and who would benefit from a comprehensive discussion of the concepts, principles, and prevailing issues of taxation. |
| principle of taxation law: Tax Law Design and Drafting: Mr. Victor Thuronyi, 1996-08-23 Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax. |
| principle of taxation law: International Commercial Tax Peter Harris, David Oliver, 2010-07-22 Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues. |
| principle of taxation law: Principles of Value Added Tax Adrian Ogley, 1998 He is also the author of Principles of International Tax. |
| principle of taxation law: Taxation and Value Creation Werner C. Haslehner, Marie Lamensch, 2021 This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework |
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