Valuing Intellectual Capital provides readers with prescriptive strategies and practical insights for estimating the value of intellectual property (IP) and the people who create that IP within multinational companies. This book addresses the crucial topic of taxation from a rigorous and quantitative perspective, backed by experience and original research that illustrates how large corporations need to measure the worth of their intangible assets. Each method in the text is applied through the lens of a model corporation, in order for readers to understand and quantify the operation of a real-world multinational enterprise and pinpoint how companies easily misvalue their intellectual capital when transferring IP rights to offshore tax havens. The effect contributes to the issues that can lead to budgetary crises, such as the so-called "fiscal cliff" that was partially averted by passage of the American Taxpayer Relief Act on New Year's day 2013. This book also features a chapter containing recommendations for a fair and balanced corporate tax structure free of misvaluation and questionable mechanisms. CFOs, corporate auditors, corporate financial analysts, corporate financial planners, economists, and journalists working with issues of taxation will benefit from the concepts and background presented in the book. The material clearly indicates how a trustworthy valuation of intellectual capital allows a realistic assessment of a company's income, earnings, and obligations. Because of the intense interest in the topic of corporate tax avoidance the material is organized to be accessible to a broad audience.

The Fund Reporting Cloud (R) has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.

You are paying much more in tax than you think you are What Everyone Needs to Know About Tax takes an entertaining and informative look at the UK tax system in all its glory to show you just how much you pay, how the money is collected and how it affects ordinary people every day. Giving context to recent controversies including the Panama Papers, tax avoidance by multinationals, Brexit and more, this book provides a straightforward explanation of tax and the policy behind it for non-specialists no accounting or legal knowledge is required. The system's underlying logic is illustrated through three 'golden rules' that explain many of the UK tax regime's oddities, and the discussion focuses on the way things are rather than utopian ideas about how they might be. Case studies show how the VAT on a plumber's bill all adds up; why fraudsters made a movie to throw HMRC off their scent; how a wealthy couple can pay so little tax on a six-figure income; and the way tracing the money you paid for your iPad sheds light why the EU is demanding Apple pay billions extra in tax. Ever the political battlefield, tax is too important for you to rely on media hype for information. It affects everyone, every day, and it pays for voters and taxpayers to know more. This book leaves aside technical detail and the arcana of the tax code to give you a real-world look at how tax works. * Learn about the many ways that the tax system separates us from our money * Discover how Brexit could change the way we pay taxes * Understand how changing tax policy affects people's everyday lives * See through the rhetoric surrounding controversies in the media With tax, we have to admit that there are no easy answers. No one enjoys paying them, but without them, the Government would shut down. Seeing through politicians' cant and superficial press coverage is critical for your ability to make the decisions that benefit you; What Everyone Needs to Know About Tax gives you the background and foundational knowledge you need to be a well-informed taxpayer.

Im Buch werden Sanierungsstrategien fur Kapitalgesellschaften vorgestellt. Das deutsche Steuerrecht kennt kein eigenes Sanierungssteuerrecht, sondern nur partielle Regelungen, die Unternehmenssanierungen in besonderem Masse wurdigen. Sanierende sind mit einer hochkomplexen Entscheidungssituation konfrontiert, die unter steuerlichen Aspekten mit erheblicher Rechtsunsicherheit verbunden ist. Der Autor untersucht die steuerlichen Rahmenbedingungen aus Verlustverrechnungsbeschrankungen, der Besteuerung von Sanierungsgewinnen und der Nichtberucksichtigung von Gewinnminderungen unter Berucksichtigung der nationalen und europaischen Rechtsprechung. Er analysiert und systematisiert typische Sanierungsinstrumente und zeigt ertragsteuerliche Optimierungsstrategien auf.

The contributions to this volume try to overcome the traditional approach of the judicature of the European Court of Justice regarding the application of the fundamental freedoms in direct taxation that is largely built on a non-discrimination test. In this volume, outstanding authors cover various aspects of the national and international tax order when European law meets domestic taxation. This includes testing traditional pillars of income taxation - ability-to-pay, source and residence, abuse of law, arm's length standard - with respect to their place in the emerging European tax order as well as substantial matters of co-existence between different tax systems that are not covered by the non-discrimination approach such as mutual recognition, cross-border loss compensation or avoidance of double taxation. The overarching goal is to flesh out the extent to which a substantive "allocation of taxing powers" within the European Union is on its way to a convincing overall framework and to stretch the discussion "beyond discrimination".

Contents Foreword, ix I. Introductory, 1 II. The Nature of Protection, 8 III. Critique of Popular, and Fallacious, Arguments for Protection, 17 IV. The Argument for Free Trade, 50 V. Rational Protection, 63 VI. Anti-dumping Legislation and Special Forms of Foreign Trade Control, 89 VII. The Future Commercial Policy of the United States, 107 Appendix I, 134 Appendix II, 150 Originally published in 1942. The Princeton Legacy Library uses the latest print-on-demand technology to again make available previously out-of-print books from the distinguished backlist of Princeton University Press. These editions preserve the original texts of these important books while presenting them in durable paperback and hardcover editions. The goal of the Princeton Legacy Library is to vastly increase access to the rich scholarly heritage found in the thousands of books published by Princeton University Press since its founding in 1905.

Taxes dominate contemporary American politics. Yet while many rail against big government, few Americans are prepared to give up the benefits they receive from the state. In Tax and Spend, historian Molly C. Michelmore examines an unexpected source of this contradiction and shows why many Americans have come to hate government but continue to demand the security it provides. Tracing the development of taxing and spending policy over the course of the twentieth century, Michelmore uncovers the origins of today's antitax and antigovernment politics in choices made by liberal state builders in the 1930s, 1940s, and 1950s. By focusing on two key instruments of twentieth-century economic and social policy, Aid to Families with Dependent Children and the federal income tax, Tax and Spend explains the antitax logic that has guided liberal policy makers since the earliest days of Franklin Roosevelt's presidency. Grounded in careful archival research, this book reveals that the liberal social compact forged during the New Deal, World War II, and the postwar years included not only generous social benefits for the middle class-including Social Security, Medicare, and a host of expensive but hidden state subsidies-but also a commitment to preserve low taxes for the majority of American taxpayers. In a surprising twist on conventional political history, Michelmore's analysis links postwar liberalism directly to the rise of the Republican right in the last decades of the twentieth century. Liberals' decision to reconcile public demand for low taxes and generous social benefits by relying on hidden sources of revenues and invisible kinds of public subsidy, combined with their persistent defense of taxpayer rights and suspicion of "tax eaters" on the welfare rolls, not only fueled but helped create the contours of antistate politics at the core of the Reagan Revolution.

The 43rd annual edition of the leading guide to taxation in Britain. This practical and user-friendly guide is a bestseller with students, professionals, accountants and private individuals, explaining in simple terms how the UK tax system works and how best to minimise tax liabilities.

This exciting new volume provides an up-to-date overview of the current state of taxation in the Latin America and Caribbean (LAC) region, its main reform needs, and possible reform strategies that take into account the likely economic, institutional, and political constraints on the reform process.

Paying taxes is one of the least popular activities worldwide. Latin America in particular is notorious for having low direct taxes, weak compliance and enforcement, and high levels of inequality. Although fiscal extraction has gained renewed interest among governments in recent years, with the end of the commodity boom adding special urgency, the successful adoption and implementation of tax reforms is easier said than done, even when tax policy prescriptions are widely shared. This volume provides the first comprehensive, region-wide assessment of the role of political factors, including public opinion, democratic institutions, natural resources, interest groups, political ideology, and state capacity. What explains the region's low levels of taxation? What explains the low progressivity in its tax structure? And what explains considerable differences across countries? In addressing these questions, each of the volume's chapters makes original theoretical and empirical contributions toward understanding how to overcome the political challenges to taxation.

This book offers a wholesale reinterpretation of both the introduction of excise taxation in Great Britain in the 1640s and the genesis of the Financial Revolution of the 1690s. By analysing hitherto unpublished manuscript and print sources, D'Maris Coffman resolves divergent accounts of these constitutionally problematic but fiscally significant new taxes. Parliament's success at imposing on a deeply divided kingdom an extra-legal species of indirect taxation, which hitherto had been a constitutional anathema and a political impossibility, remains one of the most striking features of the period. A fresh reading of William Petty's Treatise on Taxes illustrates the development of an indigenous discourse in defence of the tax state. By highlighting the importance of fiscal innovation during the Civil Wars and Interregnum for the development of the fiscal state in Britain, this study challenges 'stylised facts' about the economic significance of 1688/89. The final chapter delivers new insight into why the eighteenth-century British public accepted both unprecedented levels of government borrowing and one of the heaviest tax burdens in Western Europe. Coffman reveals how a 'new financial history,' rooted in closely contextualised studies, can contribute to current debates about sustainable levels of taxation and to fundamental questions of economic theory.

The 42nd annual edition of the leading guide to taxation in Britain. This practical and user-friendly guide is a bestseller with students, professionals, accountants and private individuals, explaining in simple terms how the UK tax system works and how best to minimise tax liabilities.

The 40th annual edition of the leading guide to taxation in Britain. This practical and user-friendly guide is a bestseller with students, professionals, accountants and private individuals; explaining in simple terms how the UK tax system works and how best to minimise tax liabilities.

This guide is a practical overview for the international businessman to understand the rules, regulations and management issues regarding taxes in China. It is written very much from practical experience. We will help you to understand the implications of what can initially appear be a complicated and contradictory subject. This book tells you the basics of what you need to know, and point you at the structures you should use to enable your China business to be both in compliance and as tax efficient as possible.

National tax authorities individually determine multinational ?rms' country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors' returns are reduced accordingly. The FASB's Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries' interpretations thereof, the U. S.

Essays on Cooperative Games collates selected contributions on Cooperative Games. The papers cover both theoretical aspects (Coalition Formation, Values, Simple Games and Dynamic Games) and applied aspects (in Finance, Production, Transportation and Market Games). A contribution on Minimax Theorem (by Ken Binmore) and a brief history of early Game Theory (by Gianfranco Gambarelli and Guillermo Owen) are also enclosed.

Preface This book contains the proceedings of the International Tax Conference on the c- th th mon consolidated corporate tax base (CCCTB) that was held in Berlin on 15 - 16 may 2007. The conference was jointly organised by the German Federal Ministry of Finance, the Centre for European Economic Research (ZEW), Mannheim, and the Max Planck Institute (MPI) for Intellectual Property, Competition and Tax Law, Munich. More than 250 participants from all over Europe and other regions, scholars, politicians, business people and tax administrators, discussed the Eu- pean Commission's proposal to establish a CCCTB. Three panels of tax experts evaluated the common tax base with respect to structural elements, consolidation, allocation, international aspects and administration. The conference made clear that the CCCTB has the potential to overcome some of the most intriguing problems of corporate income taxation within the Common Market. Common tax accounting rules substantially reduce compliance and administrative costs. Consolidation of a group's profits and losses effects cro- border loss compensation which removes a major tax obstacle for European cro- border investment. At the same time, tax planning with respect to financing and transfer pricing is pushed back within the European Union. Moreover, as far as the CCCTB applies, member states are able to remove tax provisions that are targeted at cross border tax evasion and that might be challenged by the jurisdiction of the Eu- pean Court of Justice.