Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.

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.

Table of Contents

Preface

CHAPTER 1: Introduction and Overview

(Philip Daniel, Michael Keen, Artur Swistak and Victor Thuronyi)

CHAPTER 2: Principles and Practice of International Taxation for the Extractive Industries

(Michael Keen and Peter Mullins)

CHAPTER 3: An Overview of Transfer Pricing In Extractive Industries

(Stephen E. Shay)

CHAPTER 4: Transfer Pricing – Special Extractive Industry Issues

(Jack Calder)

CHAPTER 5: International Tax and Treaty Strategy in Resource–Rich Developing Countries: Experience and Approaches

(Philip Daniel and Victor Thuronyi)

CHAPTER 6: Extractive Investments and Tax Treaties: Issues for Investors

(Janine Juggins)

CHAPTER 7: Taxing Gains on Transfer of Interest

(Lee Burns, Honoré Le Leuch and Emil M. Sunley)

CHAPTER 8: Fiscal Issues for Cross-border Natural Resource Projects

(Joseph C. Bell and Jasmina B. Chauvin)

CHAPTER 9: International Oil and Gas Pipelines: Legal, Tax, and Tariff Issues

(Honoré Le Leuch)

CHAPTER 10: The Design of Joint Development Zones Treaties and International Unitization Agreements

(Peter Cameron)

CHAPTER 11: Fiscal Schemes for Joint Development of Petroleum: A Primer and an Evaluation

(Philip Daniel, Chandara Veung and Alistair Watson)

CHAPTER 12: Taxes, Royalties and Cross-border Resource Investments

(Jack Mintz)

CHAPTER 13: Tax Competition and Coordination in Extractive Industries

(Mario Mansour and Artur Swistak)

While nearly everyone in the United States pays careful attention to the federal government in Washington, it is the state and local officials and bodies who are generally providing education, protecting the environment, caring for AIDS patients, financing affordable housing, and putting police and firefighters on the streets. In this text, Henry Raimondo gives these local governments some of the notice they are due, examining why state and local public finance has assumed such an important role in domestic fiscal policy matters. Traditional topics such as the theories of taxation and intergovernmental grants are combined with numerous overlooked subjects to reveal the dynamic and complex nature of state and local government fiscal behavior.

Raimondo begins his text with a look at the relationship between regional economic performance and state and local government finance, and follows with a description of U.S. economic geography. The organization of the public sector is outlined through a discussion of the political and economic dimensions of the federal system, and the guidelines for delegating services to different levels of government. Among the other topics covered are methods for financing elementary and secondary education that adjust for regional economic differences; taxation in a federal system; state and local taxes on property, sales, and personal income; user charges and gambling revenues; and the actual beneficiaries of state and local governments. The book concludes with an overview of the grants-in-aid system and its effect on spending decisions. Students of economics, urban studies, and political science will find this work to be an invaluable resource, as will professionals in public policy and planning.

This is the first book that performs international and intertemporal comparisons of uniform tax progression with empirical data. While conventional measures of tax progression suffer from serious disadvantages for empirical analyses, this book extends uniform measures to progression comparisons of countries with different income distributions. Tax progression is analyzed in terms of Lorenz curve and Suits curve equivalents of net incomes and taxes. The authors derive six distinct definitions of the relation "is more progressive than", which are then utilized for an empirical analysis of 13 countries included in the Luxembourg Income Study (LIS). In two thirds of all international comparisons of tax progression, the authors report a clear ranking of the respective countries in terms of progression dominance. Tax based definitions of greater progressivity perform best. These observations are yet reinforced by statistical tests. The book also provides an account of the institutional background of the involved countries in order to facilitate the interpretation of the data. Moreover, the authors conduct intertemporal comparisons of tax progression for selected countries and perform a sensitivity analysis with respect to the parameterization of the equivalence scale.

"Research on Economic Inequality, Volume 10, Fiscal Policy, Inequality and Welfare" contains ten papers, both theoretical and applied, on tax progressivity and tax and transfer equity. Theory topics covered include consumption tax equity, alternative definitions of tax progressivity, horizontal equity and reranking. The applied work includes studies of Australia's consumption taxes, Israel's national insurance tax system, Mexican transfer system, Canadian tax equity, trends in US tax and transfer progressivity and a study of the impact of the repeal of the US marriage tax penalty.

The Asian-Pacific countries as well as India and Russia offer multinational companies all the benefits of booming economies in a world of recession. However, the investor must be aware of the tax regime under which he will operate. This survey presents the rates, definitions of taxable income and the incentives available in a complete, yet concise form. It goes on to review tax minimisation strategies and concludes with a comparison of the overall tax burdens for investors in each country derived from the Devereux/Griffith formulae - a methodology well known within the EU, but applied to this region for the first time.

Master the most important areas of today's tax law with Whittenburg/Altus-Buller/Gill's best-selling INCOME TAX FUNDAMENTALS 2022. This concise, practical introduction to tax preparation uses a unique, step-by-step workbook format that integrates actual tax forms. You learn the complexities of the U.S. income tax code as this edition's clear, up-to-date presentation walks you through real, current examples using the most recent tax forms. A variety of end-of-chapter problems and online exercises offers hands-on practice with tax return problems that use source documents identical to those of real clients. Professional Intuit (R) ProConnect (TM) tax preparation software also accompanies each new book. In addition, numerous study tools and powerful online resources, including the CNOWv2 online homework tool, help you further refine your knowledge and practical skills to become a successful tax preparer today.

This is the second edition of a tax reference which brings together information on the provisions of 58 tax treaties between 12 major trading nations - Australia, Brazil, Canada, France, Germany, Italy, Japan, the Netherlands, Spain, Switzerland, UK and USA. The guide for revenue officials and tax advisors examines the background of double tax agreements and how they are brought into force. Further sections deal with matters including equipment leasing, the problem of treaty overrides and taxation of sportsmen and entertainers, and transfer pricing.;Article by article, the book reproduces the text of the the OECD Model and provides a short additional commentary. This is followed by an analysis of each countries treaties with each of the other countries dealt with in the book, including details of where they deviate from the OECD model.;"Tax Treaty Networks" also provides help in interpreting special wording used in other treaties by any of the 12 treaty partners - which should also be useful in interpreting the wording of treaties made by countries outside the present scope of the book.

On 8 November 1995 we organized the conference Is Inheritance Legitimate? Ethical and Economic Aspects of Wealth Transfers at the University of Antwerp (UFSIA). The conference brought together economists, philosophers and other social scientists to discuss the issues of bequest and inheritance. The conference programme featured five invited contributions; the revised versions of these five papers consitute the core of this book (Chapters 2, 3, 4, 6, and 7). Also included in this book are the written versions of the comments presented by the two discussants (Chapters 5 and 8). We also gave the opportunity to the authors who defended two radically different opinions on bequest and inheritance to comment upon one another's position (Chapters 9 and 10). Chapter 1 serves as an introduction; it situates the debate on inheritance in a broader ethical and economic framework, and summarizes the main points of the book. The conference was organized as part of a research project funded by the Flemish Fonds voor Wetenschap'pelijk Onderzoek (project number G. 0032. 95). Within UFSIA the conference was hosted by the 'Vakgroep Arbeidseconomie' of the Studiecentrum voor Economisch en Sociaal Onderzoek (SESO) and the Centrum voor Ethiek. The secretarial staff of SESO, in particular Annernarie Bunneghem and Linda Teunkens, did an excellent job in organizing the conference. Patricia De Bruyn and Tom Schatteman were extremely helpful in preparing the manuscript for the publisher. Antwerp, January 1997. Guido Erreygers and Toon Vandevelde, Editors CONTENTS Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The original theory of capital cost and capital structure put forward by Nobel Prize Winners Modigliani and Miller has since been modified by many authors, and this book discusses some of them. The book's authors have created general theory of capital cost and capital structure - the Brusov-Filatova-Orekhova (BFO) theory, which generalizes the Modigliani-Miller theory to encompass companies of an arbitrary age (and arbitrary lifetime). Despite the availability of this more general theory, the classical Modigliani-Miller theory is still widely used in practice. In this book, the authors for the first time generalize it for cases of practical relevance: for the case of variable profit; for the case of advance tax-on-profit payments and interest on debt payments; for the case of several tax-on-profit and interest on debt payments per period; and for the combination of all three effects. These generalizations lead to valuable theoretical results as well as significantly widen of practical application this theory in practice and increase of the quality of finance management of the company. As well, the book investigates the applications of said results in corporate finance, investments, taxation and ratings, where employing a generalized Modigliani-Miller theory can be very fruitful.

The authors provide a broad overview of economic aspects of commodity taxation, focussing in particular on theory and on policy applications in OECD countries. Some major papers in public economics have discussed whether these taxes should be levied at a uniform rate, or whether different commodities should be taxed differently, for reasons of either equity or efficiency. The authors begin with this question, and then discuss further issues, including the economic incidence of commodity taxes, the properties of the VAT, the taxation of financial services, the international aspects of commodity taxation, and environmental and health policy aspects.

This book elucidates the murky realities of China's taxation system today, and advocates bold plans for change. Theorizing finance and taxation in relation to a national political system, the authors explain the current tangled-up realities of China's creaky, inherited and uneven tax system- and put forward a plan for radical change. This book will be of interest to finance professionals, economists, and scholars of the Chinese economy. The focus is to properly handle the three basic economic and social relations between the government and the market (and the enterprises as the main market entities), between the central and local governments, and between the public power system and the citizens. This book follows the research context of problem orientation - goal orientation - practical operation, and puts forward the ideas, basic goals and paths of fiscal system reform that adapt to the modernization of national governance.

In this 30th volume of Advances in Taxation, editor John Hasseldine includes studies from expert contributors to explore topics such as: the stock market reaction to the Tax Cuts and Jobs Act; strategic repatriations made by firms; and corporate social responsibility and tax planning. Three studies separately examine individual responses to taxation including the renunciation of U.S. citizenship due to the Foreign Account Tax Compliance Act, the imposition of a tax on sugar-sweetened beverages, and the effects of social media on tax compliance in a developing country. Reporting peer-reviewed research contributions from the U.S., Canada, and Malaysia Advances in Taxation Volume 30 is essential reading for those looking to keep abreast of the most recent research, including empirical studies using a variety of research methods from different institutional settings and contexts

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.

"Charles Konigsberg has done a great service for American taxpayers-- giving all of us a clear, direct and meaningful guide to the $3 trillion of our money that goes to the government to fund programs that shape our daily lives (for better or worse.) For one used to wading through gobbledygook or impenetrable jargon, the plainspoken, straightforward actual English in this book is especially refreshing. Every American concerned about federal taxing and spending--Democrat, Republican or other, budget analyst or average citizen--should have this book." Norman Ornstein, Resident Scholar, American Enterprise Institute "This is an extremely useful book--both for those seeking a comprehensible introduction to the complexities of the federal budget and to practitioners needing a quick refresher course." Alice M. Rivlin, former Director, Office of Management and Budget, and Congressional Budget Office "Charles Konigsberg, who advised my good friend Pat Moynihan on fiscal policy, explains in clear and concise language why the United States is on a dangerous fiscal path, with entitlement programs, particularly the health care entitlements, growing at an unsustainable rate due to rapidly rising health care costs." Bob Kerrey, former Senator from Nebraska and current President of the New School ____________________________________________________________ America's Priorities explains in clear, concise, nonpartisan language how the U.S. government raises and spends $3 trillion per year. The book provides plain English explanations of the budget process, major Federal spending programs, Federal taxes, and the reasons for the major swing from deficits in the 1980s to surpluses in the late 1990s and back to rapidly increasing debt in the current decade. A broad spectrum of readers will find the book useful: journalists, political and financial commentators, the government and financial sectors, the academic community, and voters looking for a nonpartisan explanation of how our elected officials are prioritizing public resources. Charles S. Konigsberg has over two decades of bipartisan experience in the White House and U.S. Senate, having served as General Counsel at the Senate Finance Committee, Minority Chief Counsel at the Senate Rules Committee, Staff Attorney at the Senate Budget Committee, and 4 years as an Assistant Director at the Office of Management and Budget.

"Advances in Taxation" publishes articles dealing with all aspects of taxation. Articles can address tax policy issues at the federal, state, local, or international level. The series primarily publishes empirical studies that address compliance, computer usage, education, legal, planning, or policy issues. These studies generally involve interdisciplinary research that incorporates theories from accounting, economics, finance, psychology, and/or sociology. Although empirical studies are primarily published, analytical and historical manuscripts are also welcome.

The six papers in this vohune represent state-of-the-art empirical and conceptual research on various aspects of the taxation of multinational corporations. They were commissioned for and presented at a conference organized by Price Waterhouse LLP on behalf of the International Tax Policy Forum, held in Washington, DC in March, 1994. The ftrst four papers were originally published in the May, 1995 issue of International Tax and Public Finance. The Slemrod paper appeared in the Policy Watch Section of the November, 1995 issue of that journal. The foregoing papers were subject to the normal refereeing procedures of the journal, and the summaries that follow are drawn from there. The Leamer paper has not been previously published. Altshuler and Mintz examine one aspect of the 1986 u. s. Tax Reform Act --the change in the rules for the allocation of interest expense between domestic-(U. S. ) and foreign-source income. In the absence of rules, a parent with excess credits could reduce U. S. tax liability by allocating interest expense toward itself; thus reducing its taxable domestic income without any compensating increase in either the U. S. tax due on foreign-source income or the foreign tax due (which is independent of U. S. rules).