Legal Ways to Save Taxes Offshore and Onshore is an annotated checklist of tax reduction methods that are sanctioned by the U.S. tax law and will work offshore or onshore. Each method includes an indication of whether it is affected by the alternative minimum tax. Reduction methods are organized in the sequence of the personal form 1040.
Offshore Tax Strategies by Vernon Jacobs and Richard Duke is a concise, plain English introduction to the U.S. tax rules for cross border investments, foreign trusts, foreign corportions and other foreign entities owned by U.S. citizens or residents. Jacobs is a CPA with a focus on international tax law and Duke is an attorney with a concentration in international tax law.
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Understanding the Social Economy of the United States is a comprehensive introduction to the operation and study of organizations with social goals – public sector nonprofits, civil society organizations, social enterprises, cooperatives and other organizations with a social mission – under the rubric of the social economy. This text is rich in examples and case studies that explain the social economy framework in the context of the United States. The book not only highlights the differences between these organizations and traditional businesses, but also provides applied chapters on organizational development, strategic management and leadership, human resources, finance, and social accounting and accountability in social economy organizations. The perfect introduction to the social economy framework for students of nonprofit management, business, social entrepreneurship, and public policy, Understanding the Social Economy of the United States an invaluable resource for the classroom and for practitioners working in the social economy sector.
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
