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Fundamentals of Tax Policy expands the IAAO collection of core knowledge. The text is intended to provide a basic understanding and overview of the many factors that shape tax policy. This text provides a foundation for further investigation and learning on tax policy issues. This is the first book from the International Association of Assessing Officers whose sole focus is tax policy.
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
The third edition of The Fundamentals of Federal Taxation is a problem-based, transaction-oriented treatment of the basics of federal taxation. It features a balanced approach toward tax planning and tax policy and is structured for easy accessibility through the use of forty-two chapters, each of which can readily be covered in one, or occasionally two, class sessions. A new chapter in this edition brings together the various exclusions, deductions and credits concerning education. This is a topic of particular relevance to students that often receives scattered treatment in other books. Thoroughly up to date, this edition incorporates the changes arising from the American Taxpayer Relief Act of 2012, the so-called ¿fiscal cliff¿ legislation. The authors also prepare an annual supplement each August. The first half of the book provides students with an understanding of the overall structure of the federal income tax. This part culminates in two major review problems that assist students in integrating the knowledge gained. Thereafter, the book covers various major topics of taxation¿including real estate taxation, intellectual property taxation, family taxation, tax consequences of litigation, and deferred compensation -- with an emphasis on tax planning. It is designed to give students an appreciation for how the law of taxation connects with everyday events of American life. The book also contains chapters on corporate and partnership income taxation, international income taxation and the federal wealth transfer taxes in order to introduce students to those important areas of tax law. In this cogent, straightforward treatment of a complex subject, the topics, the selection of cases, and the design of the problems are all calculated to make tax fun and thought-provoking. This edition is available in both hard copy and electronic versions. A teacher¿s manual with complete solutions to all of the problems is available.
Parties to cross-border disputes arising anywhere in the vast Portuguese-speaking world – a community of more than 230 million in a space that offers a wide array of investment opportunities across four continents – increasingly seek Portugal as their preferred seat of arbitration. A signatory to all relevant international conventions, Portugal has proven to be an ‘arbitration-friendly’ jurisdiction. This volume is the first and so far only book in English that provides a thorough, in-depth analysis of international arbitration law and practice in Portugal. Its contributing authors are among the most highly regarded legal names in the country, including scholars, arbitrators, and practitioners. The authors describe how international arbitration proceedings are conducted in Portugal, what cautions should be taken, and what procedural strategies may be suitable in particular cases. They provide insightful answers to questions such as the following: What matters can be submitted to arbitration under Portuguese law? What are the validity requirements for an arbitration agreement? How do the State courts interact with arbitration proceedings and what is the attitude of such courts toward international arbitration? What are the rules governing evidentiary matters in arbitration? How is an arbitration tribunal constituted? How are arbitrators appointed? How may they be challenged? How can an international arbitral award be recognized and enforced? How does the Portuguese legal system address the issue of damages and what specific damages are admitted? How are the costs of arbitration proceedings estimated and allocated? The book includes analyses of arbitration related to specific fields of the law, notably sports, administrative, tax, intellectual property rights (especially regarding reference and generic medicines), and corporate disputes. Each chapter provides, for the topics it addresses, an examination of the applicable laws, rules, arbitration practice, and views taken by arbitral tribunals and state courts as well as those of the most highly considered scholars. As a detailed examination of the legal framework and of all procedural steps of an arbitration in Portugal, from the drafting of an arbitration agreement to the enforcement of an award, this book constitutes an invaluable resource for parties involved in or considering an international arbitration in this country. The guidance that it seeks to provide in respect of any problem likely to arise in this context can be useful to arbitrators, judges, academics, and interested lawyers.
There are many practical textbooks explaining how taxation is applied and calculated but few ever deal thoroughly with the theory behind the practice. This book concisely addresses the principles and theories behind taxation in an accessible and internationally relevant way. It encourages readers to think through and develop an understanding of why taxation is imposed, the different means by which it is imposed and the nature of the problems inherent in this imposition. It addresses background issues, fundamental principles and emerging topics such as: the philosophy and history of taxation; types of taxation; and international issues, including double taxation treaties, residence and transfer prices. This text is essential reading for students of taxation and provides a valuable introduction for students of business, finance and accounting.
This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
"Fundamentals of Income Taxation sets out the basics of income tax law in New Zealand, concentrating on substantive rules of the tax system with limited attention to procedural and administrative matters. It provides the reader with an understanding of the structure and main provisions of the Income Tax Act 2007, revenue law in its political and economic context, and the practical problems in resolving tax cases. This textbook offers summaries and conceptual analysis of statutory provisions and cases relating to them.This textbook does not provide a broad-based grounding in all aspects of revenue law, but instead deals with the core concepts of the law of income taxation as applicable to individuals and businesses. Split into six distinct parts, Fundamentals of Income Taxation covers: Essentials of income tax and its administration; The characteristics of income; Treatment of income in the tax regime; Distinguishing capital/revenue and taxable/non-taxable; Deductions; and Tax avoidance concepts, legislation, and historic and contemporary approaches"--Back cover.
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.