The Development of U.S. Tax Information Exchange Agreements (TIEAs) and Intergovernmental Agreements (IGAs)
Author: José A. Requena
Publisher:
Published: 2016
Total Pages: 68
ISBN-13:
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Interpretation Or Override? Introducing the Hybrid Tax Agreement
Author: Allison Christians
Publisher:
Published: 2015
Total Pages: 0
ISBN-13:
DOWNLOAD EBOOKIn the effort to overcome foreign law impediments to the implementation of the Foreign Account Tax Compliance Act (FATCA), the U.S. Treasury introduced intergovernmental agreements (IGAs). IGAs are hybrid tax agreements: Treaties to most of the world, in the United States they instead constitute an executive interpretation of the underlying tax treaty. This introduces a great deal of interpretive uncertainty where the terms of IGAs and tax treaties conflict. Prompted by recent queries in the EU regarding the legal nature of the IGAs, this article explores a concrete example of the legal principles at stake by examining how the public policy rules for information sharing found in US tax treaties interact with the information exchange provisions found in the IGAs.
Tax Information Exchange Agreements (TIEAs).
Author: Marta Pankiv
Publisher:
Published: 2015
Total Pages: 22
ISBN-13:
DOWNLOAD EBOOKThe Model Agreement on Exchange of Information on Tax Matters (TIEA Model) and its Commentary (TIEA Model Commentary) were published by the Organization for Economic Cooperation and Development (OECD) in 2002. Today, the OECD standard is also reflected in Article 26 OECD Model Tax Convention on Income and on Capital (OECD Model) and its Commentary (OECD Model Commentary) as well as incorporated in the United Nations Model Tax Convention (UN Model), the Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters (the CoE/OECD Convention) and European Union (EU) law. The TIEA Model contains specific provisions regarding exchange of information on request, the possibility of declining a request for information, tax examinations abroad, and a confidentiality clause. In addition, it includes provisions of an administrative nature such as allocation of costs associated with the execution of TIEAs and language usage for making and responding to requests. This contribution gives an overview of the main provisions of the TIEA Model with the focus on its content, the specificity of the information request and the application of TIEAs in practice.
Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition
Author: OECD
Publisher: OECD Publishing
Published: 2017-03-27
Total Pages: 326
ISBN-13: 9264267999
DOWNLOAD EBOOKThis publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
Taxation and Development - A Comparative Study
Author: Karen B. Brown
Publisher: Springer
Published: 2017-01-16
Total Pages: 382
ISBN-13: 3319421573
DOWNLOAD EBOOKThis volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.
International Exchange of Information in Tax Matters
Author: Xavier Oberson
Publisher: Edward Elgar Publishing
Published:
Total Pages: 352
ISBN-13: 1786434733
DOWNLOAD EBOOKThe financial crisis of 2008 and the emergence of various scandals around the world sparked a movement towards greater transparency with international exchange of information in tax matters. Fully revised and updated, this book considers the emergence of a new global standard, the automatic exchange of information. Providing a comprehensive overview of the main developments, it analyses the structure and content of the various existing instruments and models, taking into account the most up to date developments.
The Oxford Handbook of International Tax Law
Author: Florian Haase
Publisher: Oxford University Press
Published: 2023-09-22
Total Pages: 1185
ISBN-13: 0192652346
DOWNLOAD EBOOKInternational Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
Panama
Author: International Monetary Fund. Western Hemisphere Dept.
Publisher: International Monetary Fund
Published: 2016-11-02
Total Pages: 69
ISBN-13: 1475550855
DOWNLOAD EBOOKThis 2016 Article IV Consultation highlights Panama’s expected continued growth—among the strongest in Latin America—against a backdrop of low inflation, a stable financial system, and a declining current account deficit. GDP grew by 5.8 percent in 2015, and growth is projected to remain at about 6 percent in 2016 and over the medium term. The economy will be supported by the expected opening of the expanded canal and lower fuel prices. The overall fiscal deficit is expected to consolidate to 1.2 percent of GDP over the medium term. Public debt is projected as sustainable.
US Withholding Tax
Author: R. McGill
Publisher: Springer
Published: 2013-10-30
Total Pages: 340
ISBN-13: 1137317302
DOWNLOAD EBOOKThe US is the world's largest capital market. Its withholding tax system is also the most complex. This book is essential reading for investors and intermediaries trying to comply with US QI and FATCA tax regulations. It guides the reader through these complex regulations with simple and practical insights into how to meet these compliance burdens.
International Tax Evasion in the Global Information Age
Author: David S. Kerzner
Publisher: Springer
Published: 2016-11-21
Total Pages: 443
ISBN-13: 3319404210
DOWNLOAD EBOOKThis book provides a comprehensive analysis of the Organisation for Economic Cooperation and Development’s (OECD) war on offshore tax evasion. The authors explain the new emerging regulatory regimes on the global exchange of information to combat offshore tax evasion and analyse why Automatic Exchange of Information (AEOI) is not a “magic bullet” solution. Chapters include coverage of the Foreign Account Tax Compliance Act (FATCA), AEOI and the Common Reporting Standards (CRS), and the unprecedented extra-territorial enforcement by the United States of its tax and reporting laws, including the FBAR provisions of the Bank Secrecy Act. These new legal regimes directly impact nearly all financial institutions and financial service providers in the U.S., U.K., EU, Canada, and each of the 132 member jurisdictions of the OECD’s Global Forum, as well as 8 million U.S. expats. In light of The Panama Papers, this book offers a timely and valuable contribution on the prevalence and costs of international tax evasion for the global financial community, policy-makers, and practitioners alike.
