The essays analyse the interactions between tax law and tax policy. The analyses evaluate changes which presuppose the foreign tax credit mechanism, the separate taxation of corporations and their shareholders, and other basic elements in US taxation of foreign income.
Publicity about tax avoidance techniques of multinational corporations and wealthy individuals has moved discussion of international income taxation from the backrooms of law and accounting firms to the front pages of news organizations around the world. In the words of a top Australian tax official, international tax law has now become a topic of barbeque conversations. Public anger has, in turn, brought previously arcane issues of international taxation onto the agenda of heads of government around the world. Despite all the attention, however, issues of international income taxation are often not well understood. In this collection of essays, written over the past two decades, renowned tax expert Michael J. Graetz reveals how current international tax policy came into place nearly a century ago, critiques the inadequate principles still being used to make international tax policy, identifies and dissects the most prevalent tax avoidance techniques, and offers important suggestions for reform. This book is indispensable for anyone interested in international income taxation.
Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
This book addresses sixteen different reform proposals that are urgently needed to correct the fault lines in the international tax system as it exists today, and which deprive both developing and developed countries of critical tax resources. It offers clear and concrete ideas on how the reforms can be achieved and why they are important for a more just and equitable global system to prevail. The key to reducing the tax gap and consequent human rights deficit in poor countries is global financial transparency. Such transparency is essential to curbing illicit financial flows that drain less developed countries of capital and tax revenues, and are an impediment to sustainable development. A major break-through for financial transparency is now within reach. The policy reforms outlined in this book not only advance tax justice but also protect human rights by curtailing illegal activity and making available more resources for development. While the reforms are realistic they require both political and an informed and engaged civil society that can put pressure on governments and policy makers to act.
The contributors to this work, all leading economists in their own right, are a few of the many colleagues, former students, and friends of Carl Shoup who have benefitted from his many years as a leading teacher and scholar of public finance. They dedicate this book to their mentor on the occasion of his seventieth birthday, in recognition of his intellectual probity and wide influence on thinking about public finance throughout the last forty years. Matching the breadth of interest of Professor Shoup’s life-long work in the field, this collection of essays covers the range of modern thinking on public finance from theoretical concepts such as public goods to eminently practical fiscal issues like value added tax. The traditional but still relevant fiscal issues—government accounting, international taxation, taxation in developing countries, metropolitan fiscal problems, income taxation, and tax structure—are discussed along with new concerns such as modern public expenditure theory and environmental theory. The book will be a useful addition to university and college libraries and will prove invaluable to public finance scholars and others interested in modern thinking on vital fiscal issues.
The globalization of economies and the vast expansion of foreign investment have greatly increased the problems of international taxation. Musgrave (economics, emerita, U. of California-Santa Cruz) argues that cross- border tax issues should not be left to the destructive forces of tax competition but should be handled through coordinating measures of international tax agreements, thereby minimizing tax distortions in the international flow of capital while leaving countries free to determine their own tax structures. The 22 essays are drawn from a variety of publications including technical papers prepared for the government and the World Bank, books, The Columbia Journal of World Business, Tax Law Review, and other publications. Annotation copyrighted by Book News, Inc., Portland, OR
Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.