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Principles of International Taxation Angharad Miller, Lynne Oats
Publisher: BLOOMSBURY PUBLISHING

Companies operating globally pay home country tax rates that are competitive with those paid by foreign business rivals. May 15, 2014 - The changes that have occurred within the global business environment and the way in which it operates have necessitated a re-think of the traditional tax principles that have historically governed the international tax system. The experts must be very well versed with the There is an international accord on the attribution of profits earned by Permanent Establishment on the basis of 'Separate Enterprises' concept and the relevance of the 'arm's length principle'. Books; Miller, A., Oat, L., Principles of International Taxation, 2006, Tottel Publishing Ltd;; Wolf, M., Why globalisation works, 2004, Northern Phototypesetting Co. Jan 13, 2012 - Whilst it's not for ICC UK to comment on the specifics of the case, the dispute brings into question one of the key principles of international tax law—specifically, the linkage between tax jurisdiction and local residence. Apr 1, 2014 - Chief Counsel Advice (CCA) 201349015 — dated September 16, 2013, and released on December 6, 2013 — challenges this existing notion by applying transfer pricing principles to foreign tax credit (FTC) analyses of certain transactions between related parties that would not result in income for US federal In the United States, the power of the IRS to make adjustments for transfer pricing is broad and encompasses both domestic and international transactions. Nov 9, 2010 - The study of international taxation are based on the factors governing the taxation system of a particular country and being familiar with those factors is the job of an expert on international taxation. This blog posting first discusses two other U.S. PART I: BASIC PRINCIPLES OF U.S. Nov 29, 2012 - After the World War Ⅱ, the international business taxation system has been increasingly liberalized which the basic principles of international tax agreements have been laid out and spread quickly. Sep 5, 2013 - In the end, participants will have extensive knowledge in international taxation specifically regarding limits of tax-planning strategies and also the key principles underlying the taxation of cross-border activities. Feb 1, 2012 - The European Union (EU) and the Organisation for Economic Co operation and Development (OECD) have endeavoured to minimize the effect of a harmful international tax competition as it is believed to be. Mar 14, 2013 - The LIFT America Coalition will conduct an issue education campaign to raise awareness of the significant economic harm caused by our outdated international tax laws, while promoting reforms that would ensure U.S. TAXATION OF INTERNATIONAL INCOME. Multinationals with deferred foreign income. Jan 14, 2009 - This paper reviews economic principles for optimality of the taxation of international profit, from both a global and national perspective. In this paper it will be tried to come to a conclusion by .. May 31, 2013 - The book emphasizes those areas generally accepted to be essentialto tax practice. May 5, 2009 - The President's proposals demonstrate a fundamental misunderstanding of tax policy principles and of the incentives international companies face and the market forces that drive the global economy. Aug 11, 2012 - on September 22, 2012 at 1:04 pm The Wall Street Journal's Primer on Capital Gains Taxation « International Liberty. Jul 20, 2009 - The Obama administration has proposed to defer deductions for certain expenses incurred by U.S. Aug 12, 2013 - The concept of BEPS covers a range of international tax principles that are currently perceived to be operating in an unfair manner or that are being abused by sophisticated tax planners.