Credit Method Compatibility and Constraints under EU Law
Credit Method Compatibility and Constraints under EU Law

Author: Rita Julien

Publisher: Kluwer Law International B.V.

Published: 2022-01-13

Total Pages: 520

ISBN-13: 9403523646

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As European Union (EU) Member States seek to counteract base erosion and profit shifting (BEPS) practices while avoiding new obstacles to the EU’s internal market such as double taxation, the credit method, also known as the foreign tax credit, is one of the essential tools in this balancing act, yet it is one that has given rise to various EU law challenges and questions. This invaluable book – the first in-depth study of the EU law constraints on designing the credit method – delineates the EU law boundaries within which the Member States must operate when they implement this method of tax relief. For the first time, the Court of Justice of the European Union (CJEU) cases that may affect, directly or indirectly, the credit method and its main components are systematically identified and analysed in order to extract the legal findings and principles that define the contours within which the Member States can manoeuvre when considering EU-compatible approaches to the credit method. To this end, among others, this book offers: an extensive study of the historical legal developments of the credit method; an overview of the key design features of the credit method, considering the optional, variable components, such as the credit limitation (maximum creditable amount), that tailor it to different legal and policy considerations; an analysis of the legal constraints on the key features of the credit method flowing from CJEU case law on the fundamental freedoms, considering the impact of landmark cases and concepts (e.g., Schumacker, neutralization); the EU law implications based on the type of credit method (direct, indirect, imputation) and the feature of the credit method (e.g., credit limitation, credit carryforward); and examples to clearly and concisely illustrate the basic operation of the credit method and some of the main calculation and EU law issues. The author’s doctoral dissertation, on which the book is based, was awarded the Wolfgang Gassner Science Prize 2020 and the European Doctoral Tax Thesis Award 2020. As a timely, comprehensive and practical study of the relationship between the credit method and EU law, this book will be welcomed by lawyers and other professionals working with taxation matters, as well as by tax policymakers and academics in the fields of international and European tax law.

Tax Cuts and Jobs Act, Conference Report to Accompany H.R. 1
Tax Cuts and Jobs Act, Conference Report to Accompany H.R. 1

Author: Congress (U S Joint Committee on Taxat

Publisher: Government Printing Office

Published: 2018-01-08

Total Pages: 590

ISBN-13: 9780160944024

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In this report, you will find guidance about the tax rate reform legislation for working American taxpayer citizens that file Federal individual tax returns. This report outlines modifications for taxable years 2018 through 2025. Populations covered are married individuals filing joint returns and surviving spouses, head of households, unmarried individuals other than surviving spouses and heads of households, married individuals filing separate returns, estates and trusts, and more. Additionally, you will find specific tax rate information and criteria relating to deductions for qualified business income, simplification and reform of family and individual tax credits including child tax credit and new family credit, credit for elderly and permanently disabled, repeal of credit for plug-in electric drive motor vehicles, modification of deduction for home mortgage interest, modifications to the deduction for charitable contributions, reform of American opportunity tax credit and repeal of lifetime learning credit, reforms to discharge of certain student loan indebtness, repeal of deduction for student loan interest and qualified tuition and related expenses, reduction in corporate tax rate, and much more. Adult American citizens required to file Federal income taxes, small businesses and corporation owners and staff, certified public accountants, tax professionals including tax advisors and preparers, payroll staff, IRS officials and agents, members of Congress, and charitable organizations may be interested in this legislation. Students pursuing coursework in tax preparation, business accounting, tax advisory, and public finance courses may find this primary source legislation helpful for research papers and testing requirements. Related products: H.R. 1, To Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018, Title A, Individual Tax Reform produced by U.S. Senate with Amendments specifically to the repeal of sections with amendments for the Internal Revenue Code of 1986 is available here: https://bookstore.gpo.gov/products/hr-1-individual-tax-reform Jobs & Employment resources collection here:https://bookstore.gpo.gov/catalog/jobs-employment Taxes, Audits & Accounting collection here:https://bookstore.gpo.gov/catalog/taxes-audits-accounting

Model Rules of Professional Conduct
Model Rules of Professional Conduct

Author: American Bar Association. House of Delegates

Publisher: American Bar Association

Published: 2007

Total Pages: 216

ISBN-13: 9781590318737

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The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Journal of the House of Representatives of the United States
Journal of the House of Representatives of the United States

Author: United States. Congress. House

Publisher:

Published: 1975

Total Pages: 1292

ISBN-13:

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Some vols. include supplemental journals of "such proceedings of the sessions, as, during the time they were depending, were ordered to be kept secret, and respecting which the injunction of secrecy was afterwards taken off by the order of the House."