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Legal Interpretation of Tax Law' is a comprehensive multi-jurisdiction survey of the interpretation of the corporate income tax and VAT and GST or other general sales tax laws. As a result of the globalization of trade and business, tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions. Effective consulting, whether internal or external, requires not only knowledge of tax law per se but also of how tax law is explained and interpreted by the courts of foreign jurisdictions. This book is the first to deal comparatively with tax law interpretation in economies engaged in cross-border investment at a global level.00The introduction outlines the theoretical approaches to legal interpretation in general and gives an overview of issues and topics relevant to taxation ? designed to help readers understand the jurisdictional chapters that follow. Each author pays detailed attention to such documentary elements as explanatory memoranda, administrative rulings, judicial precedents, judgments of foreign courts, legislative debates, and OECD guidelines.
The emergence of crypto assets has required taxation authorities worldwide to develop unprecedented policies and compelled tax lawyers to apply existing laws in new ways. This book – the only one to focus solely on the taxation of crypto assets – provides a detailed country-by-country analysis of how the tax law of thirty-nine countries may apply to this rapidly developing area, including different use cases and compliance and documentation requirements. Following an overview of the technology and key characteristics of crypto assets, as well as the key tax concepts and types of taxes that could apply to them, leading practitioners in each particular jurisdiction summarize the relevant tax law in that country. Fully explained are such aspects of crypto assets as the following and how they are interrelated: sales; exchanges; receipt as remuneration; forks; airdrops; mining; staking; initial coin offerings; security token offerings; and initial exchange offerings. Contributors describe how each jurisdiction applies income and capital gains taxation, value-added tax and sales tax, withholding taxes, transfer taxes, and gift, inheritance, estate and wealth taxes in the context of crypto assets. Reporting requirements and enforcement are also covered. Tax law, as it applies to crypto assets, is new and continues to evolve. This book will be welcomed as the premier resource for tax practitioners, government officials, advisors, investors, issuers, users of crypto assets, and taxation academics who are seeking informed awareness of the policy choices countries make in dealing with the taxation of this new technology. Tax lawyers dealing with crypto assets will have comprehensive practical guidance on how to comply with the tax laws of multiple jurisdictions.
Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.
This guide offers expert advice on careers in tax law, including what kind of degree to get.
The American Bar Association Section of Taxation is pleased to announce the release of Careers in Tax Law: Perspectives on the Tax Profession and What It Holds for You. Designed for those considering or beginning a career in tax law, this informative guide presents a series of offerings --autobiographies in miniature--by a broad cross section of working tax professionals. Each contribution stands as a unique story of paths taken, choices made, and lessons learned. Each adds to a composite portrait of the profession and its possibilities for the next generation of tax lawyers. In essays divided thematically, over 75 tax professionals share their unique perspectives, knowledge, and experiences. Nowhere else will you find such an honest and entertaining portrayal of the tax profession and what it holds for you.
Tax Law and the Environment: A Multidisciplinary and Worldwide Perspective takes a multidisciplinary approach to explore the ways how tax policy can is used solve environmental problems throughout the world, using a multi-jurisdictional and multidisciplinary approach. Environmental taxation involves using taxes to impose a cost on environmentally harmful activities or tax subsidies to provide preferred tax treatment to more sustainable alternatives to those harmful activities. This book provides a detailed analysis of environmental taxation, with examples from around the world. As the extraction, processing and use of energy use resources is has been a major cause of environmental harm, this book explores the taxation and subsidization of both fossil fuels and renewable energy. Its analysis of the past, present, and future potential of environmental taxation will help policymakers move economies toward sustainability, as well as and informing students, academics, and citizens about tax solutions for pressing environmental issues.
Designed to cover every aspect of a United States Tax Court case from start to finish, Litigating a Case in Tax Court provides detailed guidance and tips on the Tax Court process in an easy-to-read and easy-to-use paper format with an online portal for accessing many sample documents that practitioners can use.
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.
"'Low-Income Housing Tax Credit Handbook' provides definitive guidance through the complex body of laws, regulations, and judicial decisions concerning the low-income housing credit (LIHC)"--