International Taxation of Manufacturing and Distribution


Book Description

The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.




International Taxation of Income from Services under Double Taxation Conventions


Book Description

The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.




The International Taxation System


Book Description

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.




International Taxation


Book Description




International Taxation


Book Description

International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index




International Taxation


Book Description

Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction. Information is provided for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017, this guide covers international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the United States. Key topics include: Export income Receipts in foreign currency Allocation and apportionment of deductions U.S. foreign tax credit fundamentals and special rules Initiation of foreign operations Foreign branches and affiliated companies Sale of use of tangible property Foreign business operations in the United States Foreign business sales of tangible property in the United States Foreign business provision of services in the United States Exploitation of business assets outside of the United States Use of foreign tangible/intangible property in the United States U.S. withholding taxes on foreign businesses FDII GILTI




International Taxation in a Nutshell


Book Description

This book provides an introduction to the US law of international taxation. After an introduction to the fundamentals of US international taxation and the source rules, this book addresses investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profits tax and the provisions affecting foreign investment in US real estate. Also included are chapters on US income tax treaties and filing withholding and reporting requirements. The last part of the book is directed at investment and business activities of US citizens, residents and domestic corporations outside the US. The centerpiece is a consideration of the US foreign tax credit. Intercompany pricing, controlled foreign corporations, the treatment of foreign currency, and international tax-free transactions are discussed, as well as tax arbitrage.




U.S. International Tax


Book Description

The U.S. International Tax: Core Concepts (9.0 CPE Credits) covers topics such as distinguishing the differences between various types of global tax systems and certain characteristics of each, entity classifications and different forms of operating a business in a foreign country. Valuable to anyone who needs to understand the complexities of international taxation, this U.S. International Tax: Core Concepts bundle offers you the opportunity to build a solid foundation in U.S. international taxation. The two-part series of self-study online courses is part of the U.S. International Tax Certificate, a comprehensive learning program developed in partnership with Grant Thornton geared to help global finance and accounting professionals navigate the highly complex world of international taxation. The series includes: International Tax Foundation Introduction to U.S. Outbound and Inbound Transactions WHO WILL BENEFIT? Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation KEY TOPICS Tax Systems Inbound/Outbound Taxation Residency Foreign Tax Credits Entity Classification Subpart F Income Taxable presence in U.S. Income Sourcing in U.S. Withholding taxes in U.S. Tax Treaties Transfer pricing Key Actions under OECD BEPS initiative FDII GILTI LEARNING OBJECTIVES Part 1: Distinguish the differences between various types of global tax systems and certain characteristics of each Recall how the U.S. tax system works Recall entity classification and hybrids Recognize the different forms of operating a business in a foreign country Recall the concept of a permanent establishment / taxable presence in the United States and globally Recall U.S. income sourcing rules Identify general U.S. withholding tax rules Recognize the general function and benefits of most income tax treaties Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative Part 2: Identify business transactions that generate outbound tax issues. Recognize the approach for taxing U.S. persons with foreign activities. Describe the key tax reform provisions affecting outbound transactions. Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations. Recognize foreign currency issues affecting outbound transactions. Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships. Recall effectively connected income (ECI) to a U.S. trade or business Recall the rules for sourcing of income Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP) Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT) Indicate a general framework on the U.S. withholding taxes Digital Badge: Your Professional Distinction Set yourself apart as a future-ready financial professional. Upon completion, you will be awarded with a certificate in the form of a digital badge. Digital badges allow you to distinguish yourself in the marketplace and show your commitment to quality. The badge can be posted to your social media profiles and linked to your resume or email signature, providing maximum visibility to your achievement. Credit Info CPE CREDITS: Online: 9.0 (CPE credit info) NASBA FIELD OF STUDY: Taxes LEVEL: Basic PREREQUISITES: None ADVANCE PREPARATION: None DELIVERY METHOD: QAS Self-Study COURSE ACRONYM: ITC_181_1 Online Access Instructions A personal pin code is enclosed in the physical packaging that may be activated online upon receipt. Once activated, you will gain immediate online access to the product for one full year. System Requirements AICPA’s online CPE courses will operate in a variety of configurations, but only the configuration described below is supported by AICPA technicians. A stable and continuous internet connection is required. In order to record your completion of the online learning courses, please ensure you are connected to the internet at all times while taking the course. It is your responsibility to validate that CPE certificate(s) are available within your account after successfully completing the course and/or exam. Supported Operating Systems: Macintosh OS X 10.10 to present Windows 7 to present Supported Browsers: Apple Safari Google Chrome Microsoft Internet Explorer Mozilla Firefox Required Browser Plug-ins: Adobe Flash Adobe Acrobat Reader Technical Support: Please contact [email protected].




International Aspects of the US Taxation System


Book Description

This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.




Taxmann’s International Taxation – A Compendium | 5,200+ Pages | 200+ Experts | 137 Articles | 4 Volumes | 4th Edition


Book Description

CTC’s International Tax Compendium is a collection of incisive & in-depth articles on international taxation, which serves as a reference manual and indeed, a practice guide for its readers. The current edition of the compendium is more current, more incisive, covers a broader range of topics, and like its previous three editions, promises to be another very useful tool for the following: • Tax Professionals both in India and Overseas • Judiciary and Tax administrators ought to find this a useful reference point both for technical analysis as well as for understanding the right perspective in which to view some of the international tax developments of the recent past. This compendium will equip its readers with better knowledge and practical examples to be able to serve their clients better. The current edition of the compendium is a comprehensive four volumes set, containing approximately 5,200+ pages covering all major topics on the subject of International Taxation, such as: • Amendments made in the Income-tax Act, 1961 • Changes introduced in the OECD Model Tax Convention, 2017 • Updates introduced in the OECD Model Commentary in 2017 • Updates introduced in UN Model Tax Convention in 2017 • Global Focus on combating Tax Evasion • Initiation of various Anti Avoidance Measure and tightening of Anti Money Laundering Laws • Implementation of Multilateral Instruments pursuant to the publication of the BEPS Action Plan Reports in October, 2015. The Present Publications is the 4th Edition, covering 137 Articles authored by 200+ Experts. This Compendium is a balanced collection of articles by recognised experts in the field, by young as well as eminent professionals and also by experienced and knowledgeable Commissioners of Income-tax & Senior Ex- Revenue Officials. This book is divided into four volumes, and their contents (volume-wise) are listed below: • Volume 1 & 2 contains articles explaining the following: 𝚘 Theme/basic concepts of Double Tax Avoidance Agreements 𝚘 Various Articles of Model Tax Convention 𝚘 Specific provisions of the Domestic Law dealing with the Taxation of Non-Residents and Cross-Border Transactions • Volume 3 contains industry specific articles such as: 𝚘 Taxation of Telecom Sector 𝚘 Broadcasting & Telecasting industries 𝚘 Electronic Commerce 𝚘 Foreign Banks, Offshore Funds, FII’s etc. • Volume 4 contains articles on the following: 𝚘 FEMA and other Domestic Laws such as Prevention of Money Laundering Act, Foreign Contribution Regulation Act, Black Money Act, Benami Law 𝚘 Various Anti-Avoidance Measures & other specialised articles