Nobody downloaded yet

Tax Treaties and International Taxation - Research Paper Example

Comments (0) Cite this document
Summary
This paper, Tax Treaties and International Taxation, declares that model tax treaties, in general, do not require that contracting countries coordinate their tax rates. They typically require that designated exemptions and credits are applied to earnings that are repatriated…
Download full paperFile format: .doc, available for editing
GRAB THE BEST PAPER97.3% of users find it useful
Tax Treaties and International Taxation
Read TextPreview

Extract of sample "Tax Treaties and International Taxation"

Download file to see previous pages Both the OECD Model and the UN Model provide commentary to assist in the interpretation of their respective provisions.5 The commentary to the OECD Model makes references to domestic provisions regulating anti-avoidance measures, while the UN Model does not.6 In this regard, the OECD is preferable to the UN Model for the purpose of resolving interpretive difficulties that might arise in the event national tax laws conflict with tax treaty obligations.
The definition of residence of a taxpayer can expose the taxpayer to double taxation, depending on whether or not domestic laws can be reconciled to eliminate one residence in favour of another. For instance, the national laws of more than one country might determine that a particular taxpayer is resident in their respective jurisdictions and therefore liable to tax assessment on the same income in each of these countries. The definition of residence of a taxpayer can expose the taxpayer to double taxation, depending on whether or not domestic laws can be reconciled to eliminate one residence in favor of another.  For instance, the national laws of more than one country might determine that a particular taxpayer is resident in their respective jurisdictions and therefore liable to tax assessment on the same income in each of these countries. At a joint seminar conducted by the International Fiscal Organization and the OECD, it was acknowledged that interpreting the place of effective management could give rise to two possible interpretations.  One possible interpretation is that the place of effective management could be the place where the directors typically meet.   ...Download file to see next pagesRead More
Cite this document
  • APA
  • MLA
  • CHICAGO
(Tax Treaties and International Taxation Research Paper, n.d.)
Tax Treaties and International Taxation Research Paper. Retrieved from https://studentshare.org/macro-microeconomics/1729605-tax-treaties-issues-in-international-taxation
(Tax Treaties and International Taxation Research Paper)
Tax Treaties and International Taxation Research Paper. https://studentshare.org/macro-microeconomics/1729605-tax-treaties-issues-in-international-taxation.
“Tax Treaties and International Taxation Research Paper”, n.d. https://studentshare.org/macro-microeconomics/1729605-tax-treaties-issues-in-international-taxation.
  • Cited: 0 times
Comments (0)
Click to create a comment or rate a document

CHECK THESE SAMPLES OF Tax Treaties and International Taxation

Corporation Taxation Foreign Tax Credit

...Contents Contents 2 3 Introduction 4 Credit for Foreign Income Taxes 4 Limitationon Credit 6 Maximum Allowable Foreign Tax Credit 6 Carryback and Carryover of the Foreign Tax Credit 6 Claiming the Tax Credit or Deduction Each Year 7 Foreign Taxes not eligible for the Foreign Tax Credit 7 Foreign Source Income 8 Refunds and Adjustments 8 Corporate Foreign Tax Credit Situation in the US 9 Conclusion 12 Corporation Taxation – Foreign Tax Credit Abstract This paper reveals issues that are related to foreign tax credit on corporate bodies. The discussion covers quite a number...
10 Pages(2500 words)Research Paper

International treaties Affect International Business Law

...advantage of international treaties is the possibility to outline equal conditions for all participants (both suppliers and contractors) and promote integrative, fair and transparent policy. For example, with a rapid expansion of the international trade, the US tax system has significantly changed. There are many governments which are focused on tax reforms. International players are very much focused on tax treaties to regulate misunderstandings in the area of taxes. Kirsch states the following: These treaties serve a dual purpose: they eliminate or mitigate the...
2 Pages(500 words)Essay

International Taxation

...? International Taxation Introduction The rapid globalization in the recent decades has given rise to a large number of multinational companies (MNCs) that have that have operations in several countries. The growth of international business has brought with it the challenges of harmonization of business strategies in the different geographical locations of operations. One of the most glaring challenges is the issue of taxation. In most countries, the tax unit is considered to the individual company. The local registered subsidiaries of multinational companies have to pay individual tax returns in their respective countries. Essentially,...
8 Pages(2000 words)Research Proposal

Multijurisdictional tax (Inbound taxation and Outbound taxation assignment)

...taxation of dividend income such that the maximum tax rate cannot exceed 15%. Interpretation As per Section 871(a)(1), the dividend based income of a foreign national derived from a United States source is liable to taxation. The rate of taxation on such income depends mainly on whether the individual is being charged a flat tax rate or if exceptions to such a rule exist. In case that a flat taxation rate is being charged on such income, the individual in question has to pay the relevant amount as tax as determined by United States law. However, in the case of an exception such as the existence of a bilateral...
12 Pages(3000 words)Essay

Assignment 3: International Taxation and Foreign Tax Credits

.... References De Mooij, R. A., & Ederveen, S. (2003). Taxation and foreign direct investment: a synthesis of empirical research. International Tax and Public Finance, 10(6), 673-693. Hines, J. R., & Rice, E. M. (1994). Fiscal paradise: Foreign tax havens and American business. The Quarterly Journal of Economics, 109(1), 149-182. Janeba, E. (1995). Corporate income tax competition, double taxation treaties, and foreign direct investment. Journal of Public Economics, 56(2), 311-325. Scholes, M. S., Wolfson, M. A., Erickson, M., Maydew, E., & Shevlin, T. (1992). Taxes and business strategy. Englewood Cliffs, NJ: Prentice Hall.... ?Assignment 3: International Taxation and Foreign Tax Credits...
4 Pages(1000 words)Research Paper

International Taxation - International Taxation and Foreign Tax Credits

...without increasing the volume of revenues that can be taxable under U.S. tax system. For instance, if goods are sold to buyers who are foreign nationalities, then such revenues are regarded as foreign income by the U.S. taxation system (Kogan, 2013, p.15). Accumulated earnings tax The accumulated earnings tax was first enacted in the year 1921, and the present form of the tax was imposed by Section 531 of the Internal Revenue Code of 1954. Under this Section, any income that is earned by a U.S. company which is “in excess of the reasonable needs of the business for the purpose of avoiding income tax on dividends...
6 Pages(1500 words)Research Paper

International Law, law of treaties

...goals, such as the fight against organized crime, extradition of criminals, the preservation of the environment, economic developments, protection of human rights, and scientific cooperation2. For the purpose of this research, Treaty arrangements was made the focus point for the reason of the significance developments in the International law after the emerge of The Vienna Convention on the law of treaties 1969. In fact, the international communities consider The Vienna Convention on the law of treaties 1969 as the authoritative mechanism on the international law of treaties3. With such intensive study, the research will later examine...
3 Pages(750 words)Essay

International Tax

... Assaf, R. and Sadka, E. Tax Burden and Migration: A Political Economy Perspective. CES, Münich, 1996 Brierly, J L. The Law of Nations: An Introduction to the International Law of Peace. Clarendon Press, Oxford, 1963 David C. K Monaco. Marshall Cavendish Benchmark, New York, 2008 Dennis, C. and Campbell, T.C. Legal Aspects of Doing Business in Europe. Yorkhill Law Publishing, Salzburg, Austria: 2009 Dennis, C. International Taxation of Low-Tax Transactions. BNA International, London, 2002 Dennis, C. Legal Aspects of Doing Business in Western Europe. Kluwer Law and Taxation Publishers, Deventer, Netherlands 1983 Emer, V., Chitty, J. and Ingraham, E,D. The Law of Nations, Or, Principles of the Law of Nature Applied... depends...
10 Pages(2500 words)Case Study

Tax Havens and Canadian Taxation

..., Lichtenstein, the Cayman Islands Panama, the Cook Islands, Switzerland, Mauritius, and St. Kitts and Nevis (Anderson, 2014). Pressure from foreign nations that feel the need and demand to collect all tax revenue they believe is entitled to them has forced tax havens to sign treaties that allow tax data exchange. They have also had to sign agreements that allow for the providence of investors secret information to foreign governments. How tax havens work to help lower the overall taxpayer’s bill Before we get to know how tax havens work, it is important to know the various types of offshore corporations. One of them is known as...
7 Pages(1750 words)Research Paper

International Human Rights Treaties

... International Human Rights Treaties Human rights encompass all actions whose core goal is to ensure that thelives of the citizens are at peace. They seek to promote the activities of daily living of any person devoid of their origin, nationality, ethnicity, sex, or religion. In the recent past, most countries have been on the verge of breaking up the human rights, especially due to the rifts in political ideologies. It is such occurrences that have led to the formulation of treaties of agreements, whose goal is to ensure that every person and nation stick to that agreement. The Second World War marked an end of an era where the international community constantly ignored human rights. In the light of the recent developments... of human...
5 Pages(1250 words)Essay
sponsored ads
We use cookies to create the best experience for you. Keep on browsing if you are OK with that, or find out how to manage cookies.

Let us find you another Research Paper on topic Tax Treaties and International Taxation for FREE!

Contact Us