Introduction to the Law of Double Taxation Conventions
Introduction to the Law of Double Taxation Conventions

Author: Michael Lang

Publisher: Linde Verlag GmbH

Published: 2021-04-01

Total Pages: 266

ISBN-13: 3709408628

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The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.

Income Tax
Income Tax

Author: B. B. Lal

Publisher: Pearson Education India

Published: 2010

Total Pages: 708

ISBN-13: 9788131732281

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Estate Planning and Drafting
Estate Planning and Drafting

Author: JEFFREY N. PENNELL

Publisher: West Academic Publishing

Published: 2020-10-22

Total Pages: 817

ISBN-13: 9781647086596

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Updated through August 1, 2020, the third edition of Pennell's Estate Planning and Drafting focuses on every-day planning for "middle-rich" clients. For example: Traditional planning for couples who may not have as much wealth as double the basic exclusion amount but who anticipate that the exclusion amount may decline in the future. They must consider whether to qualify 100% of the estate of the first to die for the marital deduction (and defer all taxes), or instead to shelter the unified credit of the first to die in a nonmarital trust. In either case they also need to decide whether to elect portability for any unused exclusion amount. A sharper focus on family trust planning for clients with enough wealth to worry about protecting their beneficiaries (and wealth) but for whom sophisticated tax-minimization techniques are not needed. A new brief explanation of Code Chapter 14 illustrates its application but notes that most middle-rich clients will not stumble into estate freezing techniques. The coverage of retirement benefits is updated to reflect the SECURE Act changes to the required-minimum-distribution rules, and elimination of most stretch-payout planning. The chapter on charitable giving is streamlined and simplified in recognition that most middle-rich clients do not make extensive use of private foundations or split-interest trusts. Information about postmortem planning and fiduciary administration stresses state and federal income taxation and state death taxation in situations that do not trigger federal wealth transfer taxation. The text explains essential tax fundamentals that inform traditional techniques (e.g. Crummey powers), without overemphasis on the tax-oriented practices that led to their original adoption. There are over 100 pages of annotated forms illustrating basic planning documents, including a pour over will, self-trusteed declaration of trust, irrevocable life insurance trust, family and marital deduction trusts, and a third-party special needs trust.