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A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
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.