Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition. Unquestionably, the most important development in international tax since the publication of the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition explores in detail both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. Also new to the fifth edition are sections dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: taxation of residents on foreign income and nonresidents 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. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international 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.

As countries worldwide have become more economically integrated, The importance of international taxes has grown significantly, especially in countries formerly part of the Soviet Union or the Soviet bloc. The authors of this book worked with the OECD in conducting seminars on international tax for tax officials in these countries. In International Tax Primer, they address international aspects of income taxation in particular countries, emphasising tax treaties and other cooperative arrangements which help coordinate countries' income tax systems with the tax systems of their trading partners. International Tax Primer strikes a balance between the specific And The general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes: The role of the tax adviser, tax planning techniques, international double taxation, anti-avoidance rules, and an overview and analysis of tax treaties. The work also offers such practical features as : An extensive glossary of international tax terms; and a selected bibliography of international tax reference materials, including a list of periodicals devoted to international tax. Students, government officials, and tax practitioners who may be confronting international tax issues For The first time, As well as experienced international tax practitioners, will find International Tax Primer a helpful articulation of the fundamental principles that arise again and again in this field. it works as both an introduction and a refresher in an area where issues often prove more complex than they seem and where a return To The basics is often the most helpful means of untangling a multi-layered problem.

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental 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 nonresidents 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. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international 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.

This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.

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].

'The chapters in this book explore in detail the choices regarding both the structure and administration of the property tax, drawing on the extensive knowledge the authors have acquired in studying property taxes around the world. The chapters provide a wide-ranging treatment of the design choices and administrative tasks, both in terms of the breadth of design options and administrative tasks covered and the depth of the discussion. The authors describe the range of design choices, discuss the associated issues and the advantages and disadvantages for each, and present the criteria to help choose among the options.’ From the book’s Foreword by David L. Sjoquist, Professor of Economics and Dan E. Sweat Scholar Chair in Educational and Community Policy, Georgia State University Property taxation is a key element in providing a solid foundation and a stable funding source for basic public services. Developing and implementing a property tax system is a complex task. This complexity is compounded by the diversity of legal, cultural and historical contexts of policymakers and tax administrators. The World Development Report (1999-2000), Entering the 21st Century puts fiscal decentralization at the top of the development agenda. This makes local taxation - and especially the property tax option - of critical importance to both tax and land policy, as well as the broader development agenda. A Primer on Property Tax: Administration and Policy provides the reader with an analysis of issues surrounding property tax, including economics, law, public finance, decentralisation, valuation, GIS and property tax reform. A key strength of the book lies in the vast international experience of the authors and the book will provide for the first time material which is topical, cutting-edge and highly relevant to many of the disciplines involved in property taxation. The authors examine the criteria applied to evaluate the strengths and weaknesses of property tax, discuss the main valuation methods and the economic principles underpinning them and review the legal and administrative aspects of property tax worldwide.

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.

This is the first in a series of articles providing a primer on international planning for domestic estate planners and tax practitioners. This first part begins by providing a broad overview of the international tax paradigm, opening with the transfer tax regime, moving on to the individual income tax regime and, finally, addressing the taxation of trusts in cross-border transactions.

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.