The Double Taxation of Dividend Income

The Double Taxation of Dividend Income

Author: Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation

Publisher:

Published: 1953

Total Pages: 16

ISBN-13:

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Book Synopsis The Double Taxation of Dividend Income by : Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation

Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation and published by . This book was released on 1953 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Dividends in Relation to Income Tax

Dividends in Relation to Income Tax

Author:

Publisher:

Published: 1918

Total Pages: 42

ISBN-13:

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Download or read book Dividends in Relation to Income Tax written by and published by . This book was released on 1918 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Basis of Assets

Basis of Assets

Author: United States. Internal Revenue Service

Publisher:

Published:

Total Pages: 12

ISBN-13:

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Book Synopsis Basis of Assets by : United States. Internal Revenue Service

Download or read book Basis of Assets written by United States. Internal Revenue Service and published by . This book was released on with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Dividends Under the Income Tax

Dividends Under the Income Tax

Author: Daniel Mark Holland

Publisher:

Published: 1962

Total Pages: 218

ISBN-13:

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Book Synopsis Dividends Under the Income Tax by : Daniel Mark Holland

Download or read book Dividends Under the Income Tax written by Daniel Mark Holland and published by . This book was released on 1962 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924

Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924

Author: United States. Internal Revenue Service

Publisher:

Published: 1924

Total Pages: 396

ISBN-13:

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Book Synopsis Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924 by : United States. Internal Revenue Service

Download or read book Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924 written by United States. Internal Revenue Service and published by . This book was released on 1924 with total page 396 pages. Available in PDF, EPUB and Kindle. Book excerpt:


The International Tax Law Concept of Dividend

The International Tax Law Concept of Dividend

Author: Marjaana Helminen

Publisher: Kluwer Law International B.V.

Published: 2017-05-02

Total Pages: 306

ISBN-13: 9041183957

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The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.


Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen

Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.


Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States

Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States

Author: International Monetary Fund

Publisher: International Monetary Fund

Published: 1990-07-01

Total Pages: 64

ISBN-13: 1451961928

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The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.


Book Synopsis Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States by : International Monetary Fund

Download or read book Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States written by International Monetary Fund and published by International Monetary Fund. This book was released on 1990-07-01 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.


Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924

Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924

Author: United States. Department of the Treasury

Publisher:

Published: 1924

Total Pages: 392

ISBN-13:

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Book Synopsis Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924 by : United States. Department of the Treasury

Download or read book Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924 written by United States. Department of the Treasury and published by . This book was released on 1924 with total page 392 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Author: Guglielmo Maisto

Publisher: IBFD

Published: 2012

Total Pages: 1093

ISBN-13: 9087221398

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This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.


Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto

Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.


Final Report of the Committee on the Federal Corporate Net Income Tax

Final Report of the Committee on the Federal Corporate Net Income Tax

Author: National Tax Association. Committee on the Federal Corporate Net Income Tax

Publisher:

Published: 1950

Total Pages: 52

ISBN-13:

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Book Synopsis Final Report of the Committee on the Federal Corporate Net Income Tax by : National Tax Association. Committee on the Federal Corporate Net Income Tax

Download or read book Final Report of the Committee on the Federal Corporate Net Income Tax written by National Tax Association. Committee on the Federal Corporate Net Income Tax and published by . This book was released on 1950 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt: