Multinational corporations face different tax systems in different countries that require careful tax planning. A systematic approach is needed to minimize and avoid unnecessary business taxes. Some core issues of international taxation are part of a successful corporate tax plan in an international context. The first issue is a good understanding and appreciation of the principles of international taxation that include the different philosophies of taxation, the different kinds of taxes, the different tax systems, the different tax treaties and potential tax havens. The second issue is a thorough understanding of U.S. taxation of foreign income to avoid double taxation and the computation of foreign tax credits. The third issue is the choice of a transfer pricing method and the compliance with tax regulations on both the transfer of tangible and intangible assets. The fourth issue is the intelligent use of tax vehicles for exporting which can generate substantial savings and reduce the effective tax rate and involve the choice between the interest-charge domestic international sales corporation and the foreign sales corporation. A final issue is the efficient use of value-added taxation for activities taking place outside the U.S., and a new appreciation of the potential of this form of taxation for the United States. Practicing accountants, academics, business executives, students, legislators, and others who want a better understanding of the complex issues of international taxation will be interested in this book.

This book provides an insight into commercial relations between large economies and Small States, the benefits of regional integration, the role of Small States as financial centres as well as B2B and State to State dispute resolution involving Small States. Several contributions allow the reader to familiarise themselves with the general subject matter; others scrutinise the particular issues Small States face when confronted with an international dispute and discuss new and innovative solutions. These solutions range from inventive ideas to help economic growth to appropriate mechanisms of dispute resolution including inter-State dispute resolution and specific areas of arbitration such as tax arbitration. Researchers, policy advisors and practitioners will find a wealth of insights, information and practical ideas in this book.

The US tax and reporting rules applicable to foreign trusts - principally embodied as Subchapter J of the Internal Revenue Code of 1986, as amended - are notoriously complex. Now, with this volume, anyone who has to deal with these rules can find their use and meaning clearly explained, and proceed confidently to the best outcome in any situation where they apply. This guide covers all the following topics in detail: regular nongrantor (or accumulation) trusts of both the "simple" variety and the "complex" type with its challenging "throwback" rules and interest charge on accumulation distributions; the circumstances under which certain foreign trusts, such as section 672(f) (barring the application of the normal grantor trust rules to certain foreign trusts), section 643(h) (relating to distributions by certain foreign trusts through nominees), and section 643(i) (relating to loans from foreign trusts); reporting and penalty provisions and the accompanying IRS forms; and special issues, such as those surrounding incoming immigrants and outgoing expatriates. The book provides modified versions of the principal IRS forms (3520, 3520-A, 4970, 1040NR, and 1041) that are commonly filed for foreign trusts. These modifications, which scrupulously follow all applicable IRS rules, are much easier to use than the actual forms for the purpose of foreign trusts. Numerous examples throughout the book clarify the valid procedures and alternatives available at every point, a feature particularly useful in applying provisions that still await settled regulation and case law. Compliance issues that may arise on IRS audit are also examined. Professionals and advisors in law, tax, accounting, banking, and securities; settlers and beneficiaries; and students and academics both within and outside the United States should find this an informative and useful volume.

This book showcases the practical insights of some of Europe's foremost tax advisers and lawyers on recent case law issuing from the European Court of Justice. It also provides readers with informed analysis on how the Court may rule on future controversies impacting direct taxation.This timely and useful resource will examine each of the following topics, inter alia: CFC Legislation and Abuse of Law in the Community; free movement of capital and non-member countries; consequences for direct taxation; striking a proper balance between the national fiscal interests and the community interest; a perpetual struggle; personal income taxation of non-residents and the increasing impact of the EC Treaty Freedoms; why the European Court of Justice should interpret directly applicable Community law as a right to most-favoured nation treatment and a prohibition of double taxation; fiscal cohesion, fiscal territoriality, and Preservation of the (Balanced) Allocation of Taxing Power; what is the difference? limitation of the Temporal Effects of Judgments of the ECJ; Tax Facilities for State-induced Costs under the State Aid Rules; and EU Law and rules of tax procedure.

What are the implications and likelihood of reform of the income tax system in the United States—specifically, the expansion and scope of the tax "expenditure" (loophole) system embedded in the income tax codes? This book details the tax system that now provides for more than 200 tax expenditures, highlighting the potential lost tax dollars. Income tax policy and politics is an inherently complex and potentially confusing topic. This book makes the tax loophole system understandable for those without in-depth knowledge about taxes. It explains what our tax system looks like, why it is set up as it is, and what effects it has on raising revenue (and thus deficits) and the furtherance of other policy goals. Additionally, it explains why, despite popular and political desires, a significant overhaul of the tax system is very unlikely to be enacted: because tax expenditures (otherwise known as loopholes) benefit all Americans in some way and are supported as policy by both political parties. Written by John F. Witte, an established expert in tax policy and policy analysis, the book provides a balanced viewpoint that discusses the implications of reform of the income tax system in the United States, demonstrates the range of individuals who are affected by various provisions, and identifies what effects loopholes have on policy goals. Readers will see how both political parties are responsible for the creation and expansion of various loopholes, understand why many of these provisions make sound policy sense, and grasp how the tax code is affected by political desires and policy goals.

The increasing international mobility of capital, firms and consumers affects tax policies in most OECD countries, playing a major role in reforming national tax systems. Haufler uses standard microeconomic analysis to consider the fundamental forces underlying this process. Topics include a variety of different international tax avoidance strategies--capital flight, profit shifting in multinational firms, and cross-border shopping. Haufler addresses the issue of coordination in different areas of tax policy, with emphasis on regional tax harmonization in the EU. Also included is a detailed introduction to recent theoretical literature.

This book is open access under a CC BY 4.0 license. This book takes a taxpayer's perspective on the relations taxation creates between people and their state. Bjoerklund Larsen proposes that in order to understand tax compliance and cheating, we have to look beyond law, psychological experiments and surveys to also include tax collectors and taxpayers' practices. The text explores the view of taxes seen as citizen's explicit economic relation to the state and implicit economic relation to all other compatriots. Bjoerklund Larsen directs our gaze onto the concept of reciprocity, which is often proposed as an explanation in tax compliance research, and explores its diverse meanings and implications ethnographically. The empirical cases are based on ethnography from two opposing tax practices in Sweden. Firstly, from a study of analysts, auditors, legal experts and managers at the Swedish Tax Agency and how they, quite successfully, strive for legitimacy in their tax collecting activities. Secondly, from fieldwork among a group of middle-aged Swedes and how they justify their purchasing work off the books - essentially tax-cheating practices. Sweden is a modern welfare society with citizens holding rational and secular values, yet trusting their government and fellow citizens. Sweden also has a high tax burden that is collected by one of its most revered governmental agencies - the Swedish Tax Agency - making it an interesting case studying tax compliance.

Third countries are not bound by European law; however, saying that EU Member States are not bound by European law in their relations with third countries would be incorrect. The judicial developments of European tax law based on the application of fundamental freedoms by the European Court of Justice has turned relations with third countries into one of the most controversial areas of European tax law, giving rise to a significant degree of legal uncertainty. The first waves of direct tax cases decided by the ECJ on the relations with third countries have not entirely solved the main critical issues arising in such context, including the ones involving the external scope of fundamental freedoms. Consequently, the expert analysis contained in this book will be of significant interest to many international tax practitioners and academics throughout the world.
Among the vitally important areas this book addresses...
- The external scope of Article 56 EC Treaty and its impact on the relations with third countries
- The indirect impact of other fundamental freedoms on the relations with third countries
- The scope of fundamental freedoms in relations to EEA States under the EEA Agreement
- The relations with other third countries in the field of direct taxes (including, among other, EPAs countries)
- The impact of the EU agreements on the direct tax relations between Switzerland and the EU Member States
- The impact of secondary EC law on the relations with third countries in the field of direct taxes
- The scope of Article 307 EC Treaty and its application in the field of direct taxes
- The external treaty making powers of the European Union in the field ofdirect taxes.

The 1980s and 1990s were a watershed in terms of both tax and monetary policy. The 1981 Reagan tax cut ushered in supply-side economics, while the 1986 Tax Reform Act produced a substantial cut in the marginal individual income tax rate. In terms of monetary policy, the Volcker-Greenspan chairmanships of the Federal Reserve initiated fundamental changes in monetary policies that lowered inflation. Jankowski examines both tax and monetary policies to determine their effects on profits. He shows that the pretax profit rate fell in the post-World War II year, but that the post-tax profit rate remained relatively constant. However, Jankowski argues that the tax policies adopted did not produce the observed constancy in the post-tax profit rate. He further argues that the elimination of the corporate income tax would have the effect of enhancing redistributive policies. Jankowski's analysis of tax and monetary policies leads to new theories of the state and classes, and he argues that the growth of the state has restructured classes. The state, and not the workplace, has become the locus of income for the majority of individuals in modern capitalist societies. This change requires a fundamental rethinking of the nature of classes and class politics. A controversial analysis that will be vital reading for economists, political scientists, and other scholars and policymakers dealing with tax and monetary issues.

This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts.

This volume describes how various types of taxes such as VATs, corporate income taxes, retail sales taxes, and excise taxes are being modified to achieve environmental goals. The author gives particular focus to situations in which taxes are imposed on imports and where rebates are granted when domestic products are exported. These taxes are evaluated with respect to exceptions to GATT and how these exceptions can be used to create powerful tax initiatives even though they might be considered "GATT-illegal". The book shows how to integrate economically effective environmental taxes and tax subsidies with the major international trade treaties. Tax initiatives can be an important tool to improve the free trade system while at the same time combating environmental depredation. Manufacturers, exporters, tax and environmental policy makers, international trade and tax attorneys, and academics working in the fields of environmental regulation, trade policy, and taxation should find this work a provocative treatise on this topic.

Professor Martin Daunton's major work of original synthesis explores the politics of taxation in the "long" nineteenth century. In 1799, income tax stood at 20% of national income; by the outbreak of the First World War, it was 10%. This equitable exercise in fiscal containment lent the government a high level of legitimacy, allowing it to fund war and welfare in the twentieth century. Combining new research with a comprehensive survey of existing knowledge, this book examines the complex financial relationship between the State and its citizens.

Although considerable information about China's tax policies on foreign investment have been made available in the West, this book is the first to provide a comprehensive treatment of China's domestic system of taxation. It offers an authoritative analysis of each type of taxation and the tax system as a whole, within the broader context of the nation's economic and fiscal structure. Written by one of the foremost authorities on the subject, it benefits from the author's access to important Chinese materials as well as personal contacts with Chinese government officials and Western lawyers and businessmen working in China.

Tracing the evolution of taxation in China from the early feudal period to the present, the author reviews the long history of various forms of taxation, some of which have been in existence for thousands of years. Jinyan Li next looks at the use of taxation as an instrument of the socialist economy in the years immediately following the Communist revolution, during the period of closed central planning, and in the recent movement toward an open market economy. Current tax policy is analyzed in six chapters, each dealing with a specific form of taxation. Throughout the book, the author explores the relationship of tax policy to other aspects of the Chinese economy, including economic planning, price and wage policies, the state budget and financial system, and government policies regarding property ownership and private enterprise. This book will be an important information source for scholars, students, and tax lawyers concerned with socialist fiscal policy and China's current economic reforms.

The overall objective of the book is to holistically assess the property tax systems in BRICS megacities. As megacities play a vital role within their respective countries - economically, administratively, and from a human development perspective - they experience the costs and benefits of urbanization simultaneously with major investment needs, rising poverty, and increasing congestion and pollution levels in the context of limited financial resources, raising the question for a suitable decentralized funding source. This book highlights the property tax as a means to help further improve the financial sustainability of megacities, the reliability and quality of their services, and megacities' contribution to supporting economic growth.

Examining the benefits achieved by deferring income or accelerating deductions, this text refers to the income tax systems of the United States and Japan. The United States has been at the forefront of recognizing the time value of money benefit of tax deferral and of devising methods to prevent tax deferral. Japan, on the other hand, is only gradually placing greater emphasis on tax deferral issues, in light of the activities of foreign companies, and the constant introduction of new financial products which take advantage of the tax deferral allowed under Japanese income tax rules. The book starts with a detailed discussion of the 1948 Cary Brown model and its various interpretations, an understanding of which is key to any analysis of tax deferral issues. The author goes on to provide a comparative analysis of the different tax deferral patterns that can arise under the United States and Japanese income tax systems, and of methods introduced by the United States to eliminate the tax deferral benefit. A history and overview of the Japanese income tax system is included in the appendix. Principles of tax deferral and time value of money are crucial in an era of globalization in commerce and finance. They cut across all areas of taxation and are particularly important in the context of taxation of derivatives and other financial instruments.

This book provides a detailed assessment of current approaches to transfer pricing in the context of small- and middle-sized enterprises (SMEs), including the newest update of Transfer Pricing Guidelines from 10 July 2017. It analyzes the transfer pricing rules for SMEs across the European Union (EU) and explores two alternative approaches as suitable solutions for current transfer pricing issues. The authors evaluate and discuss alternative approaches like Safe Harbour and Common Consolidated Corporate Tax Base (CCCTB). Taking into account the prominent role of SMEs in the European Union's economy, the book also puts forward policy recommendations to achieve the long-term goals of the EU's 2020 agenda.

Despite the globalization of accounting standards occurring through convergence to International Financial Reporting Standards, local accounting systems are deeply intertwined with each country's unique institutions such as its corporate system, disclosure practices and enforcement mechanisms. First, this book empirically analyzes the effects of globalization and localization of accounting rules on corporate behavior such as earnings management, signaling, investment behavior and dividend payout policy. Second, the book unravels the economic consequences of disclosure based on the concept of self-disciplining enforcement such as management forecasts, environmental disclosures and risk disclosures by Japanese firms. This volume is a step forward in understanding the link between accounting and corporate behavior based on a new institutional accounting approach.

Though frequently used interchangeably, the terms tax-exempt organization and nonprofit organization do not carry the same legal definition. Nonprofit enterprises are those that do not distribute earnings in the form of dividends or distributions, so while all tax-exempt organizations are nonprofit, not all nonprofit organizations are necessarily tax-exempt. This work provides a comprehensive look at the federal Internal Revenue code governing tax-exempt status, carefully detailing the criteria specified in the code and related Treasury Regulations. Also outlined are the presribed procedures for filing for tax-exempt status.

Robert N. Sughrue and Michelle L. Kopnski present a thorough discussion of the various types of tax-exempt organizations and the characteristics unique to each. Sections 501(c), 521, 527, and 528 of the Internal Revenue Code are closely analyzed, and the organizational tests of 501(c)(3) institutions are provided. In addition, accounting systems for tax-exempt organizations, internal controls, and reporting requirements are also covered. Among the other topics addressed by Sughrue and Kopnski are unrelated business taxable income, private foundations, financial considerations in tax-exempt and other nonprofit organizations, and financial considerations and practical applications. Students and professionals in the fields of finance, investment, accounting, and law will find this work to be a useful reference tool, and academic, public, and law libraries will consider it a worthwhile addition to their collections.

During the past decade the issue of a general welfare double dividend (an improvement in environmental quality combined with a positive welfare effect) triggered by a tax shift from labour to energy resources has been extensively debated. In this book, Kurt Kratena studies the employment effects of revenue neutral tax shifts from labour to energy, and measures the impact on theoretical and empirical models of the European labour market. A common theoretical framework is devised to analyse the impact of environmental tax reform. Various 'labour market regimes' (competitive labour markets, union wage bargaining and efficiency wages) are derived and taken as the starting point for different specifications of the labour market. The theoretical outcomes of tax shifts in these different labour market regimes are then analysed and compared. The results reveal that whereas an econometric based multi-sectoral model yields significant double dividend effects, a general equilibrium model only finds employment double dividend effects. The book also highlights the potentially positive economic consequences of environmental tax reform such as a shift in demand from energy to non-energy goods. This book provides a concise appraisal of the general double dividend question combined with an innovative analysis of the employment double dividend effect. It utilises extensive empirical evidence and reveals the sensitivity of the various theoretical concepts surrounding the debate. This book will be of interest and relevance to academics in the fields of environmental economics, labour theory and fiscal studies.

This user-friendly book aims to summarize the principal topics of Chinese Taxation and offers readers a general overview of the Chinese Taxation and informative updates on tax changes. The book provides a variety of facts, figures, graphs and data in an easy-to read table format. Firstly, the book proposes an introduction to taxation and to the Chinese tax system, secondly, it focuses on direct taxes, indirect taxes and other taxes and, in the end, it covers international taxation. Moreover, the book offers a quick overview of the Chinese M&A taxation and of the Chinese Free Trade Zones.