• Aliens

International Tax and Estate Planning

A Practical Guide for Multinational Investors
Author: Robert C. Lawrence
Publisher: N.A
ISBN: N.A
Category: Aliens
Page: 850
View: 7229

    • Business & Economics

Multistate and Multinational Estate Planning


Author: Jeffrey A. Schoenblum
Publisher: CCH
ISBN: 9780808092285
Category: Business & Economics
Page: 2632
View: 3243
Multistate and Multinational Guide to Estate Planning analyzes the legal aspects of individual wealth transfers across state and national boundaries. In addition, the Guide seeks to develop workable strategies for the attorney involved with a multijurisdictional client.

    • Business & Economics

Practical Guide to U.S. Taxation of International Transactions (11th Edition)


Author: Michael S. Schadewald,Robert J. Misey
Publisher: N.A
ISBN: 9780808050247
Category: Business & Economics
Page: N.A
View: 7108
Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

    • Business & Economics

The Principles of International Tax

A Multinational Perspective
Author: Adrian Ogley
Publisher: International Information Services Incorporated
ISBN: 9780952044208
Category: Business & Economics
Page: 186
View: 6232
This work on international tax aims to strip away the mystique that can surround the subject. International tax is now recognised as an important discipline in its own right. The book sets out to synthesise its most important elements.

    • Law

Fixing U.S. International Taxation


Author: Daniel N. Shaviro
Publisher: Oxford University Press
ISBN: 019935975X
Category: Law
Page: 223
View: 2184
Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.

    • Copyright

Catalog of Copyright Entries. Third Series

1973: January-June
Author: Library of Congress. Copyright Office
Publisher: Copyright Office, Library of Congress
ISBN: N.A
Category: Copyright
Page: 1862
View: 5533

    • Business & Economics

Transfer Pricing and Developing Economies

A Handbook for Policy Makers and Practitioners
Author: Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher: World Bank Publications
ISBN: 1464809704
Category: Business & Economics
Page: 388
View: 7580
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.

    • Business & Economics

Global corporate real estate management

a handbook for multinational businesses and organizations
Author: Mary Alice Hines
Publisher: N.A
ISBN: N.A
Category: Business & Economics
Page: 262
View: 3050
Written for corporate real estate managers, this is a comprehensive practical guide to the selection, management, and disposal of corporate real estate properties in both the home and foreign countries. The author focuses on the management of the real assets of U.S.-based multinationals, although the discussion can be applied to multinational company management of worldwide real estate regardless of headquarters country. Among the key topics addressed are the ways in which a corporate real estate department can be most effectively organized, the need for computerization in the management of diverse properties in a variety of locations, leasing property, tax management, risk analysis and management, and real estate performance measurement. Throughout, the author includes details of the actual experiences of leading U.S. multinationals to illustrate the unique problems associated with various national and local real estate markets around the globe. Hines begins by offering some suggestions for corporate policy formulation aimed at guiding decisionmaking in the acquisition, development, and divestiture of property related to company operations. She addresses the lease-or-buy decision, demonstrating that the decision depends on the nature of the corporate real assets, the need for security, and the availability of funds. A separate chapter addresses the widely varying leasing conditions and terms that are encountered around the world. Since income, value-added, sales, withholding, and ad valorem property taxes affect country and site selections as well as company profitability, Hines provides an in-depth treatment of tax management from the perspective of the corporate real estate decisionmaker. Global real estate risk management also receives extended coverage. The final chapter shows how to measure real estate performance and demonstrates that global real estate holdings can and should be viewed as global portfolios with overall returns and risks--rather than as individual buildings with individual profit-and-loss profiles.

    • Business & Economics

International Taxation in America for the Entrepreneur


Author: Brian Dooley
Publisher: CreateSpace
ISBN: 9781495290718
Category: Business & Economics
Page: 134
View: 7491
When you are reading "International Taxation in America for the Entrepreneur," you'll learn to redefine your meaning of the word "Taxation" ...that elusive "something" that is an inherent problem in so many of your businesses...and you'll gain the insight of how to move beyond the myths and the barriers that can cause your "bottom line" to be adversely affected. Today's entrepreneurs are finding cross border business planning is easier than ever before. The cross border business and the multinational family are using offshore "foreign trusts" for tax planning, inheritance planning and asset protection. "International Taxation in America for the Entrepreneur" is explains the tried and true international tax plans of successful businesses. It is designed for the busy business owner. The book has the blueprints of the best foreign tax structures. Besides international tax planning articles, tax treaties, rulings, regulations and leading court cases, you have access to our Custom Google site that includes more than 300,000 hidden pages on the IRS web site and our blog. Brian Dooley, CPA, MBT has been specializing in offshore taxation since 1980. He has helped numerous accountants and attorneys serve a broad range of individual and business clients in various international tax and estate planning matters. Also, he has on nine occasions offered expert witness testimony before the U.S. Department of Treasury and the U.S. House of Representatives on issues related to foreign investments, foreign trusts and private annuities. Mr. Dooley is the founder of International Tax Counselors. His firm brings together a team of attorneys and certified public accountants. With a passion for perfection, the firm assist foreign individuals investing in the United States and Americans with their foreign businesses. Brian Dooley can be contacted at [email protected] He specializes in assisting other CPA's and law firms with their clients international tax issues. You can learn more about his services at www.IntlTaxCounselors.com. His experience includes: * Obtaining private letter rulings and voluntary disclosure agreements from the IRS * Resolving (on an anonymous basis) undisclosed cross-border tax issues with the IRS * Advising attorneys and CPA's, since 1976, on 100's of international tax audits and IRS agreements, * Developing tax-efficient international estate plans * Implementing strategies that minimize cross-border taxes Expertise Brian's forte is obtaining written IRS rulings on tax planning strategies to guarantee savings. He also excels in counseling chartered accountants, CPAs and attorneys in international tax law. He is highly skilled in using the IRS tax-amnesty program, private letter rulings, foreign business tax credits and offshore trusts to help clients: * Achieve their international tax and estate planning objectives * Protect themselves from audits, penalties and unpleasant tax surprises * Avoid IRS tax controversy * Set up captive insurance companies * Deal with foreign inheritances * Immigrate into the United States or open a U.S. office for a foreign company Publications * Estate Planning with a Foreign Trust * Contributing author to Taxation of International Transactions, edited by Matthew Bender Involvements * American Institute of Certified Public Accountants, Member * California Society of Certified Public Accountants, Member Education B.S. in Accounting and Masters in Business Taxation from the University of Southern California.

    • Business & Economics

International Taxation Handbook

Policy, Practice, Standards and Regulations
Author: Colin Read
Publisher: Elsevier
ISBN: 0750683716
Category: Business & Economics
Page: 369
View: 8220
International taxation is evolving in response to globalization, capital mobility, and the increased trade in services, and introduces international tax practitioner, student and researcher to the theory, practice, and international examples of the changing landscape. Models of tax competition in a flat and connected world are very different than those necessary to ensure compliance in a world dominated by cross-border flows of goods and repatriation of profits. Taxes on consumption, e-commerce, and services are looming innovations in future of international taxation. Tax coordination and standardization are immense challenges in a world in which the movement of value is increasingly subtle and hard to detect. And as corporations and individuals become more sophisticated in the internationalization of flows of capital, our models must become more sophisticated in their scope and inclusion. In the era when trade was dominated by the exchange of manufactured goods, international taxation was designed to protect domestic industries, create tax revenue, prevent evasion, and promote compliance. The traditional toolbox of customs duties, tariffs, and taxes on repatriated profits must be augmented as the movement of goods across borders represents a much smaller fraction of trade and as international taxation policy is increasingly used to attract foreign corporations rather than discourage branch offices. International taxation models that can better tax services, track international flows of capital, and allow a nation to compete in a world market for capital formation are the tools of the modern tax practitioner. International tax policy is now viewed as an integral part of economic policy. This approach is bound to accelerate as the world becomes increasingly flat and better connected. Economic progress is more and more influenced by the movement of services and information, movements that are no longer through ports but through fiber optic lines. This book contributes to the growing literature on international taxation by bringing together theory and experience, current practices and innovation, and our current understanding of some of the challenges now facing and arguably frustrating current international taxation policy. The book will create new avenues of research for scholars, a new awareness for students of International Taxation, and new possibilities for international tax practitioners. The models and examples presented here suggest that there are serious problems with measurability of flows of services and information, and points to an increasingly need for greater harmonization of international taxation, perhaps through coordinated consumption-tax oriented approaches. * Describe the rapidly evolving role of International Taxation in a globalizing information economy * Present theoretical models that act as the basis for successful international tax competition * Describe the experiences and innovations of representative internationalized countries * Discuss some new approaches to International Taxation * Makes the case for new models of international taxation in an increasingly global information world

    • Law

Estate Planning & Chapter 14

Understanding the Special Valuation Rules
Author: Cheryl E. Hader
Publisher: Practising Law Institute
ISBN: 9780872241350
Category: Law
Page: 473
View: 1959
Estate Planning & Chapter 14 highlights the transfers that are exempt from the application of 2701 covering the transfer tax treatment of accumulated qualified payments; transfers that are exempt from the application of 2702 covering transfers of interest in trusts; adjustments that can be made under 2701 to avoid double taxation; and types of transfers under 2702 that minimize the risk of double taxation.

    • Business & Economics

Fit for Growth

A Guide to Strategic Cost Cutting, Restructuring, and Renewal
Author: Couto,Deniz Caglar,John Plansky
Publisher: John Wiley & Sons
ISBN: 1119268532
Category: Business & Economics
Page: 288
View: 1359
A practical approach to business transformation Fit for Growth* is a unique approach to business transformation that explicitly connects growth strategy with cost management and organization restructuring. Drawing on 70-plus years of strategy consulting experience and in-depth research, the experts at PwC’s Strategy& lay out a winning framework that helps CEOs and senior executives transform their organizations for sustainable, profitable growth. This approach gives structure to strategy while promoting lasting change. Examples from Strategy&’s hundreds of clients illustrate successful transformation on the ground, and illuminate how senior and middle managers are able to take ownership and even thrive during difficult periods of transition. Throughout the Fit for Growth process, the focus is on maintaining consistent high-value performance while enabling fundamental change. Strategy& has helped major clients around the globe achieve significant and sustained results with its research-backed approach to restructuring and cost reduction. This book provides practical guidance for leveraging that expertise to make the choices that allow companies to: Achieve growth while reducing costs Manage transformation and transition productively Create lasting competitive advantage Deliver reliable, high-value performance Sustainable success is founded on efficiency and high performance. Companies are always looking to do more with less, but their efforts often work against them in the long run. Total business transformation requires total buy-in, and it entails a series of decisions that must not be made lightly. The Fit for Growth approach provides a clear strategy and practical framework for growth-oriented change, with expert guidance on getting it right. *Fit for Growth is a registered service mark of PwC Strategy& Inc. in the United States

    • Business & Economics

Taxes & Business Strategy


Author: Myron S. Scholes,Mark A. Wolfson,Merle M. Erickson,Edward L. Maydew,Terrence J. Shevlin
Publisher: Pearson Higher Ed
ISBN: 0133845761
Category: Business & Economics
Page: 576
View: 8225
This is the eBook of the printed book and may not include any media, website access codes, or print supplements that may come packaged with the bound book. For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience–for you : Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide you with relevant examples from both classroom and real-world consulting experience. Learn the practical uses for business strategy: Learn important concepts that can be applied to your life. Reinforce learning by using in-depth analysis: Analysis and explanatory material help you understand, think about, and retain information.


    • Law

Principles of International Taxation


Author: Angharad Miller,Lynne Oats
Publisher: A&C Black
ISBN: 1847668798
Category: Law
Page: 649
View: 8219
This superb book will guide the reader through the key issues and practical aspects of international tax practice. It demonstrates how different global tax systems interact and how to prevent paying more tax than necessary. The basic principles of each aspect of international taxation are outlined and then examined in greater depth and detail. This updated third edition includes coverage of both UK and EU legislation and regulation, as well as the key cases and rulings. Complicated double taxation concepts are clearly illustrated with examples and diagrams to help the reader quickly understand how they'll apply in practice. Examples of policies adopted in other countries are included, along with specialist commentary and guidance.

    • Double taxation

Taxation of Cross-border Partnerships

Double Tax Relief in Hybrid and Reverse Hybrid Situations
Author: Jesper Barenfeld
Publisher: IBFD
ISBN: 9076078858
Category: Double taxation
Page: 406
View: 3037
Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other."

    • Business & Economics

Ten Steps to a Results-Based Monitoring and Evaluation System

A Handbook for Development Practitioners
Author: Jody Zall Kusek,Ray C. Rist
Publisher: World Bank Publications
ISBN: 0821389076
Category: Business & Economics
Page: 264
View: 8817
This Handbook provides a comprehensive ten-step model that will help guide development practitioners through the process of designing and building a results-based monitoring and evaluation system.

    • Business & Economics

The Quest for Value


Author: G. Bennett Stewart
Publisher: Harper Collins
ISBN: 0887304184
Category: Business & Economics
Page: 800
View: 4928
In this bestselling classic of financial management, G. Bennett Stewart, III, raises and answers these provocative questions: Do dividends matter? Are earnings per share really accurate measures of corporate performance? What is the engine that really drives share prices? More than that, Stewart lays the foundation for EVAr, the financial management and incentive system now in place at nearly 300 companies around the world, and which is rapidly becoming the global standard for corporate governance. Managers, confused about what investors really want, often find it difficult to reach informed decisions regarding business strategy, acquisitions and divestitures, financial structure, dividend policy, and executive compensation. But now an EVAr -based revolution is providing a practical framework that managers can use to build a premium-valued company. At the forefront of this revolution is the consulting firm of Stern Stewart & Co., of which G. Bennett Stewart, III, author of The Quest for Value, is senior partner and cofounder. The Quest for Value is written for senior management, key operating people, and planning and financial staff. This bible of financial management will assist managers in goal setting, resource allocation, strategy development, valuation of acquisitions, financial policy setting, incentive compensation planning, and building shareholder value. The Quest for Value cuts sharply through the myths that to this day misinform corporate strategists in their pursuit of shareholder value. Laying waste to inaccurate yet widely used methods of performance, Stewart demonstrates how the Stern Stewart EVAr approach not only creates greater shareholder value but also provides a powerful framework for the broadest range of corporate decision making.

    • International business enterprises

International Tax Primer


Author: Brian J. Arnold
Publisher: N.A
ISBN: 9789041159755
Category: International business enterprises
Page: 250
View: 7886
International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. This third edition has been expanded substantially, due to the major developments that have occurred since the second edition of this indispensable resource appeared in 2004 - not least the fact that innumerable smalland medium-sized firms, as well as individuals, now engage in cross-border transactions that cause them and their tax advisers to confront international tax issues on a regular basis. Moreover, as the countries of the world have become increasingly integrated economically, the importance of the major issues that a country must confront in designing its international tax rules and in coordinating those rules with the tax systems of its trading partners has mushroomed. The book strikes a balance between the specific and the general by illustrating the funda mental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: * role of the tax adviser in planning international transactions; * taxation of residents on foreign income and of non-residents on domestic income; * mechanisms used to mitigate the risks to taxpayers of international double taxation; * transfer pricing rules to prevent the avoidance of tax by multinational corporations; * anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; * overview and analysis of the provisions of bilateral tax treaties and the OECD and UN * Model Treaties on which they are generally based; and * challenges posed by taxation of income derived from the digital economy. New material in the third edition includes analysis of the OECD's initiative against base erosion and profit shifting (BEPS), tax aspects of hybrid entities and financial instruments, and taxation of fees for technical services as proposed under the UN Model Treaty. Although of greatest value to tax practitioners and government officials confronting interna tional tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.

    • Business & Economics

International Accounting and Transnational Decisions


Author: S. J. Gray
Publisher: Butterworth-Heinemann
ISBN: 1483135683
Category: Business & Economics
Page: 512
View: 4330
International Accounting and Transnational Decisions explores a wide range of significant international accounting issues with special reference to the comparative development of national systems of accounting, international accounting standards, transnational financial reporting issues and financial planning and control in the multinational corporation. The book is organized into five parts. Part I discusses the international dimensions of accounting including both the financial reporting and managerial decision-making perspectives. The second part is concerned with the comparative international aspects of accounting. The Part III presents developments and questions relating to international accounting standards. The fourth part considers a number of selected transnational financial reporting issues of concern both to managers and financial statement users. The last part takes a managerial perspective in its coverage of important problems of transnational financial decision making and control. Accountants and students of accounting will find the book useful.