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International Taxation in a Nutshell: A Concise Guide for Businesses and Individuals
Navigating the complex world of international taxation can feel like traversing a minefield. Whether you're a multinational corporation expanding overseas or an individual with foreign income, understanding the intricacies of global tax laws is crucial to avoid costly mistakes and potential legal issues. This comprehensive guide provides a simplified overview of international taxation, offering a "nutshell" understanding of key concepts and considerations. We'll demystify the complexities, making the subject accessible to both businesses and individuals.
H2: Understanding the Fundamentals of International Taxation
International taxation deals with the tax implications of cross-border transactions and activities. Unlike domestic taxation, which primarily focuses on a single country's tax laws, international taxation involves navigating the tax systems of multiple jurisdictions. This often includes complexities like double taxation treaties, tax havens, and varying tax rates on income, capital gains, and other assets. The core principle governing international taxation is the concept of tax residency, which determines which country has the right to tax an individual or entity's income.
H3: Key Concepts to Grasp:
Tax Residency: This determines where you are legally obligated to pay taxes. Residency rules vary greatly by country, often considering factors such as the number of days spent in a country, permanent home, and citizenship.
Double Taxation Treaties (DTTs): These agreements between countries aim to prevent double taxation – the scenario where the same income is taxed twice in two different countries. DTTs often establish mechanisms like tax credits or exemptions to alleviate this burden.
Permanent Establishment (PE): This refers to a fixed place of business through which a business conducts its activities. Establishing a PE in a foreign country can trigger tax obligations in that country, regardless of the company's primary location.
Transfer Pricing: This involves setting prices for goods and services exchanged between related entities in different countries. International tax laws often regulate transfer pricing to prevent tax avoidance through artificial price manipulation.
Tax Havens: These are countries or territories with exceptionally low or no corporate income tax rates. Utilizing tax havens can raise compliance issues and attract scrutiny from tax authorities.
H2: International Taxation for Businesses
Multinational corporations (MNCs) face significantly more complex tax challenges than domestic businesses. They need to manage tax obligations in multiple jurisdictions, comply with varying tax regulations, and strategically optimize their global tax burden.
H3: Key Considerations for Businesses:
Foreign Direct Investment (FDI): Investing in foreign markets often involves navigating the tax implications of setting up subsidiaries, branches, or joint ventures. This requires careful planning and understanding of local tax laws.
Cross-border transactions: Sales, purchases, and other transactions with entities in different countries involve specific tax considerations, including VAT/GST, customs duties, and withholding taxes.
Compliance and Reporting: MNCs must comply with tax regulations in all jurisdictions where they operate. This includes accurate tax reporting, record-keeping, and potentially engaging specialized international tax professionals.
Tax Optimization: While minimizing tax liabilities is legitimate, aggressive tax avoidance techniques are illegal and can lead to severe penalties. Legitimate tax optimization strategies often involve careful planning and structuring of international operations.
H2: International Taxation for Individuals
Individuals with international income, such as those working abroad, receiving foreign pensions, or owning foreign assets, also need to be aware of the tax implications.
H3: Key Considerations for Individuals:
Foreign Earned Income Exclusion: Many countries offer tax breaks for citizens working abroad. Understanding these exclusions is vital for accurately calculating your tax liabilities.
Foreign Tax Credits: These credits can reduce your domestic tax liability on foreign-source income.
Reporting Foreign Assets: Individuals must generally report their foreign bank accounts and assets to their tax authorities, even if they don't owe taxes on them.
Gifting and Inheritance: International tax laws govern the transfer of assets across borders, including inheritance and gift taxes.
H2: Seeking Professional Advice
Navigating the complexities of international taxation can be overwhelming. Seeking guidance from qualified international tax professionals is highly recommended. These experts possess in-depth knowledge of international tax laws and can assist with compliance, optimization, and dispute resolution. They can help you avoid costly mistakes and ensure you remain compliant with all relevant regulations.
Conclusion:
International taxation is a multifaceted area demanding careful consideration. Understanding the key concepts and seeking professional advice are crucial for both businesses and individuals engaging in cross-border activities. By grasping the fundamentals outlined in this guide, you can build a stronger foundation for navigating the international tax landscape effectively and minimizing potential risks.
FAQs:
1. What is the difference between tax avoidance and tax evasion? Tax avoidance is legally minimizing your tax liability through permitted strategies, while tax evasion involves illegal activities to avoid paying taxes.
2. How do I determine my tax residency status? Residency rules vary by country; consult the specific tax laws of the relevant countries or seek professional advice.
3. What are the penalties for non-compliance with international tax regulations? Penalties can include significant fines, interest charges, and even criminal prosecution.
4. Do I need a specialized international tax accountant? While not always mandatory, it is highly recommended for complex international tax situations to ensure compliance and optimization.
5. Where can I find information about specific country's tax laws? You can generally find this information on the respective country's government tax authority website.
| international taxation in a nutshell: International Taxation in a Nutshell Richard L. Doernberg, 2007 This book provides an introduction to the US law of international taxation. After an introduction to the fundamentals of US international taxation and the source rules, this book addresses investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profits tax and the provisions affecting foreign investment in US real estate. Also included are chapters on US income tax treaties and filing withholding and reporting requirements. The last part of the book is directed at investment and business activities of US citizens, residents and domestic corporations outside the US. The centerpiece is a consideration of the US foreign tax credit. Intercompany pricing, controlled foreign corporations, the treatment of foreign currency, and international tax-free transactions are discussed, as well as tax arbitrage. |
| international taxation in a nutshell: International Taxation in a Nutshell MINDY. HERZFELD, Richard Doernberg, 2018-08-31 This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised and updated to address the fundamental changes to the U.S. international tax rules introduced by the 2017 tax act, as well as global tax changes brought about by the OECD's project on cross-border tax avoidance. In addition to providing a survey of the technical rules, the book also offers insight into tax planning considerations and how these have been altered by recent U.S. and global developments. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In today's world, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. The authors' careers span both the academic and private sectors, and they have used their experiences to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts. |
| international taxation in a nutshell: 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. |
| international taxation in a nutshell: International Taxation in Canada Jinyan Li, Arthur J. Cockfield, J. Scott Wilkie, 2018 |
| international taxation in a nutshell: Research Handbook on International Taxation Yariv Brauner, 2020-12-25 Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas. |
| international taxation in a nutshell: International Taxation in an Integrated World Jacob A. Frenkel, Assaf Razin, Efraim Sadka, 1991 In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy. |
| international taxation in a nutshell: International Taxation and Multinational Activity James R. Hines, 2009-02-15 Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe. |
| international taxation in a nutshell: A Practical Guide to U. S. Taxation of International Transactions Robert Meldman, Michael S. Schadewald, 1997 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. |
| international taxation in a nutshell: International Taxation of Banking John Abrahamson, 2020-02-20 Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications. |
| international taxation in a nutshell: International Taxation Joseph Isenbergh, 2006 |
| international taxation in a nutshell: Corporate Income Taxes under Pressure Ruud A. de Mooij, Mr.Alexander D Klemm, Ms.Victoria J Perry, 2021-02-26 The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics. |
| international taxation in a nutshell: Fixing U.S. International Taxation Daniel N. Shaviro, 2014-04 Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations. |
| international taxation in a nutshell: Taxation and Gender Equity Caren Grown, Imraan Valodia, 2010 Around the world, there are concerns that many tax codes are biased against women, and that contemporary tax reforms tend to increase the incidence of taxation on the poorest women while failing to generate enough revenue to fund the programs needed to improve these women's lives. Because taxes are the key source of revenue governments themselves raise, understanding the nature and composition of taxation and current tax reform efforts is key to reducing poverty, providing sufficient revenue for public expenditure, and achieving social justice. This is the first book to systematically examine gender and taxation within and across countries at different levels of development. It presents original research on the gender dimensions of personal income taxes, and value-added, excise, and fuel taxes in Argentina, Ghana, India, Mexico, Morocco, South Africa, Uganda and the United Kingdom. This book will be of interest to postgraduates and researchers studying Public Finance, International Economics, Development Studies, Gender Studies, and International Relations, among other disciplines. |
| international taxation in a nutshell: Federal Income Taxation of Partners and Partnerships in a Nutshell Karen C. Burke, 1999 Common Law and Equitable Remedies for Breach of Contract; Expectation Damages; Restitution; Reliance Damages; Specific Performance; Contracts for the Sale of Goods: Buyers' and Sellers' Remedies Under Article II of the UCC; Remedies Available to Buyer When He Has Not Accepted the Goods; Remedies Available to Buyer After He Has Accepted the Goods, Including Remedies for Breach of Warranty; Remedies Available to Seller When Buyer Defaults and Has Not Accepted the Goods; Remedies Available to Seller After Buyer has Accepted the Goods; Contractual Control Over Remedy; Liquidated Damages Clauses; Contractual Modification or Limitation of Remedy Under UCC 2-719; Remedies for Mistake and Unconscionability; Mistake in the Formation of an Agreement -- The Recission and Restitution Remedies; Mistake in Integration or Expression The Reformation Remedy: Mistake in Performance of an Obligation The Restitution Remedy; Unconscionability. |
| international taxation in a nutshell: International Tax Policy Tsilly Dagan, 2018 Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just. |
| international taxation in a nutshell: 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. |
| international taxation in a nutshell: Taxing Profit in a Global Economy Michael P. Devereux, Alan J. Auerbach, Michael Keen, Paul Oosterhuis, John Vella, Wolfgang Schön, 2020-09-29 The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers. |
| international taxation in a nutshell: 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 in a nutshell: International Law of Taxation Peter Hongler, 2021 In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these. |
| international taxation in a nutshell: State and Local Taxation and Finance in a Nutshell M. David Gelfand, Peter W. Salsich, 1985 |
| international taxation in a nutshell: The International Taxation System Andrew Lymer, John Hasseldine, 2012-12-06 International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading. |
| international taxation in a nutshell: Employment Law Review Erika C Collins, 2017-04-07 The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK |
| international taxation in a nutshell: International Taxation in the Age of Electronic Commerce Jinyan Li, Canadian Tax Foundation, 2003 |
| international taxation in a nutshell: Federal Income Taxation of Individuals in a Nutshell John K. McNulty, 1988 Introduction to US law of federal income taxation of individuals. Includes material on tax credits, mark-to-market regimes, original-issue discount, consumption- vs. accretion-model income taxation. |
| international taxation in a nutshell: The Public International Law of Taxation Asif H. Qureshi, Ajay Kumar, 2019-05-22 The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally. |
| international taxation in a nutshell: International Company Taxation Ulrich Schreiber, 2013-01-30 The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance. |
| international taxation in a nutshell: Taxation of S Corporations in a Nutshell Douglas A. Kahn, Jeffrey H. Kahn, 2020-10-07 The Subchapter S rules are complex. This book describes the basic rules that apply to S corporations and their shareholders with sufficient detail to alert the reader to potential pitfalls. The topics covered include: (1) the qualification requirements for a Subchapter S election, (2) the allocation of tax items among the shareholders, (3) the effect of those allocations on a shareholder's basis in stock and debt, (4) the limitations on the deduction of pass through items, (5) the treatment of corporate distributions, (6) the voluntary and involuntary termination of Subchapter S status, (7) the treatment of the year in which a Subchapter S election is terminated, (8) the limited availability of certain Subchapter S provisions after a Subchapter S election is terminated, (9) the taxation of an S corporation's passive investment income and built-in gains, and (10) the business income deduction. The discussion of these issues is supplemented by numerous examples. |
| international taxation in a nutshell: 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. |
| international taxation in a nutshell: Federal Income Taxation of Estates, Trusts, and Beneficiaries in a Nutshell GRAYSON M.P. MCCOUCH, 2020-03-09 This comprehensive guide can serve either as a course supplement or as a refresher for members of the bar. Expert commentary summarizes the law and offers critical perspectives on the federal income taxation of estates, trusts, and beneficiaries, including the decedent's final income tax return; classification of estates and trusts; income in respect of a decedent; distributable net income; simple and complex trusts; distributions; grantor trusts; charitable trusts; and foreign trusts. Additional chapters cover basic income, gift and estate tax concepts, accumulation distributions, and specially treated trusts. |
| international taxation in a nutshell: International Taxation Nigam Nuggehalli, 2019-11-26 This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation. The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts. Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area. |
| international taxation in a nutshell: International Taxation and the Extractive Industries Philip Daniel, Michael Keen, Artur Świstak, Victor Thuronyi, 2016-09-23 The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics. |
| international taxation in a nutshell: Imposing Standards Martin Hearson, 2021 The problem with tax treaties -- A history of developing countries in (and out of) global tax governance -- Turning the tables: the competition discourse and north-south relations -- OECD knows best: the expert view of tax treaties -- The United Kingdom -- Zambia -- Vietnam and Cambodia -- Historical legacies in a rapidly changing world. |
| international taxation in a nutshell: International Taxation of Trust Income Mark Brabazon, 2022-06-30 In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the 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. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty. |
| international taxation in a nutshell: Taxation of International Transactions Charles H. Gustafson, Robert J. Peroni, Richard Crawford Pugh, 2011 Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules. |
| international taxation in a nutshell: International Taxation Philip F. Postlewaite, Stephanie Renee Hoffer, 2010 This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions. |
| international taxation in a nutshell: U.S. International Taxation Joel D. Kuntz, 1991 |
| international taxation in a nutshell: 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. |
| international taxation in a nutshell: Income Tax Law Vern Krishna, 2012 This book is a comprehensive, up-to-date treatise on income tax law in Canada. The book introduces students and practitioners to income tax law in its broadest dimensions. It addresses the subject matter based on principles, policy, and practice. The objective is to explain what the law is, why it is the way it is, and how it works (or does not). |
| international taxation in a nutshell: Double Taxation and the League of Nations Sunita Jogarajan, 2018-05-10 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. |
| international taxation in a nutshell: International Company Taxation and Tax Planning Dieter Endres, Christoph Spengel, 2015 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. |
International Taxation In A Nutshell [PDF] - netsec.csuci.edu
International Taxation in a Nutshell: A Concise Guide for Businesses and Individuals Navigating the complex world of international taxation can feel like traversing a minefield. Whether you're …
International Taxation In A Nutshell 11thnbsped
International Taxation in a Nutshell Richard L. Doernberg,2007 This book provides an introduction to the US law of international taxation After an introduction to the fundamentals of US …
International Taxation In A Nutshell - obiemaps.oberlin.edu
introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated to address the fundamental …
International Taxation In A Nutshell
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 …
International Taxation In A Nutshell [PDF]
International Taxation in an Integrated World Jacob A. Frenkel,Assaf Razin,Efraim Sadka,1991 In this book the authors provide a new treatment of international taxation one that focuses on the …
International Taxation In A Nutshell (PDF)
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 …
International Taxation In A Nutshell 11thnbsped (2024)
In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business …
International Taxation In A Nutshell - drupal8.pvcc.edu
International Taxation in a Nutshell (Nutshells) This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners …
International Taxation In A Nutshell Nutshell Ser (book)
International Taxation in a Nutshell Richard L. Doernberg,2007 This book provides an introduction to the US law of international taxation. After an introduction to the...
International Taxation In A Nutshell Nutshell Ser (book)
Tax Policy in a Nutshell CHRISTOPHER H. HANNA,2022 Description Coming Soon International Taxation in a Nutshell Richard L. Doernberg,2009 Offers a concise exposition of the United …
Course Syllabus Template - Fredric G. Levin College of Law
This course is a survey course in U.S. international taxation. We will begin with an introduction to the basic principles of international taxation, including jurisdiction, nexus, and source and the …
International Taxation In A Nutshell Copy
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, …
International Taxation In A Nutshell - elearning.nict.edu.ng
Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised and …
International Taxation In A Nutshell
a complex network of international transactions within multinational groups and with international customers This book provides a thorough practical analysis of international taxation issues as …
Introduction to U.S. International Taxation Professor Mindy …
This course is a survey course in U.S. international taxation. For the first half of the course, we will focus on the taxation of non-U.S. persons with tax nexus in the U.S.
BASICS OF INTERNATIONAL TAXATION - bangaloreicai.org
What is international tax? State A. Movement. Carrying on of a business activity. Earning of Income. State B. Residence. Connecting factor is residence. Unlimited taxing rights due to …
International Taxation In A Nutshell (2024)
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 …
International Taxation In A Nutshell Full PDF
straight forward presentation of the key international tax concepts Publisher International Taxation in a Nutshell Richard L. Doernberg,2009 Offers a concise exposition of the United States tax …
International Taxation In A Nutshell - elearning.nict.edu.ng
Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised and …
International Taxation In A Nutshell Nutshells En
This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised
International Taxation In A Nutshell [PDF] - netsec.csuci.edu
International Taxation in a Nutshell: A Concise Guide for Businesses and Individuals Navigating the complex world of international taxation can feel like traversing a minefield. Whether you're …
International Taxation In A Nutshell 11thnbsped
International Taxation in a Nutshell Richard L. Doernberg,2007 This book provides an introduction to the US law of international taxation After an introduction to the fundamentals of US …
International Taxation In A Nutshell - obiemaps.oberlin.edu
introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated to address the fundamental …
International Taxation In A Nutshell
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 …
International Taxation In A Nutshell [PDF]
International Taxation in an Integrated World Jacob A. Frenkel,Assaf Razin,Efraim Sadka,1991 In this book the authors provide a new treatment of international taxation one that focuses on the …
International Taxation In A Nutshell (PDF)
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 …
International Taxation In A Nutshell 11thnbsped (2024)
In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business …
International Taxation In A Nutshell - drupal8.pvcc.edu
International Taxation in a Nutshell (Nutshells) This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners …
International Taxation In A Nutshell Nutshell Ser (book)
International Taxation in a Nutshell Richard L. Doernberg,2007 This book provides an introduction to the US law of international taxation. After an introduction to the...
International Taxation In A Nutshell Nutshell Ser (book)
Tax Policy in a Nutshell CHRISTOPHER H. HANNA,2022 Description Coming Soon International Taxation in a Nutshell Richard L. Doernberg,2009 Offers a concise exposition of the United …
Course Syllabus Template - Fredric G. Levin College of Law
This course is a survey course in U.S. international taxation. We will begin with an introduction to the basic principles of international taxation, including jurisdiction, nexus, and source and the …
International Taxation In A Nutshell Copy
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, …
International Taxation In A Nutshell - elearning.nict.edu.ng
Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised and …
International Taxation In A Nutshell
a complex network of international transactions within multinational groups and with international customers This book provides a thorough practical analysis of international taxation issues as …
Introduction to U.S. International Taxation Professor Mindy …
This course is a survey course in U.S. international taxation. For the first half of the course, we will focus on the taxation of non-U.S. persons with tax nexus in the U.S.
BASICS OF INTERNATIONAL TAXATION - bangaloreicai.org
What is international tax? State A. Movement. Carrying on of a business activity. Earning of Income. State B. Residence. Connecting factor is residence. Unlimited taxing rights due to …
International Taxation In A Nutshell (2024)
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 …
International Taxation In A Nutshell Full PDF
straight forward presentation of the key international tax concepts Publisher International Taxation in a Nutshell Richard L. Doernberg,2009 Offers a concise exposition of the United States tax …
International Taxation In A Nutshell - elearning.nict.edu.ng
Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised and …
International Taxation In A Nutshell Nutshells En
This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been extensively revised
