Corporate Income Taxes under Pressure
Corporate Income Taxes under Pressure

Author: Ruud A. de Mooij

Publisher: International Monetary Fund

Published: 2021-02-26

Total Pages: 388

ISBN-13: 1513511777

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The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

The Taxation of Companies 2021
The Taxation of Companies 2021

Author: Tom Maguire

Publisher: Bloomsbury Publishing

Published: 2021-04-09

Total Pages: 2718

ISBN-13: 1526513730

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This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland. Written by Tom Maguire, this new edition is updated to the Finance Act 2020. An extremely practical book, it features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your client's tax liabilities as low as possible. Updates included in this edition are: - The Finance Act 2020 provisions on transfer pricing exclusions, albeit subject to Ministerial order at time of writing - Discussions on Revenue guidance issued on various provisions in previous year e.g. hybrid transactions An overview of recently decided case law at the courts and at the Tax Appeals Commission Discussion of certain Covid-19 related provisions.

Feeney: The Taxation of Companies 2019
Feeney: The Taxation of Companies 2019

Author: Michael Feeney

Publisher: Bloomsbury Publishing

Published: 2019-04-19

Total Pages: 2416

ISBN-13: 1526506920

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This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland. Now in its 23rd year of publication, this extremely practical book features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your clients' tax liabilities as low as possible. This new edition has been updated to the Finance Act 2018 and incorporates the many substantive legal changes that have taken place in the last year, including: - The new controlled foreign companies legislation: whereby, for Irish tax purposes, undistributed income of controlled foreign subsidiaries may be attributed to an Irish controlling company of those subsidiaries. - The capital gains tax exit charge legislation, which has been completely re-written and substituted for the existing legislation. - Film relief, which has been extended for another four years, to 31 December 2024, but which has also been extensively amended There have also been numerous legal smaller changes that have been addressed and incorporated into this new edition, such as the technical change in specified tangible assets to the 80% restriction on allowable capital allowances, the extension of accelerated capital allowances to expenditure on energy-efficient equipment, the accelerated capital allowances for equipment and buildings for childcare centres or fitness centres for employee and the extension of relief for start-up companies.

Feeney: the Taxation of Companies 2020
Feeney: the Taxation of Companies 2020

Author: Tom Maguire

Publisher: Bloomsbury Professional

Published: 2020-02-27

Total Pages: 2432

ISBN-13: 9781526509772

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This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland.This year, for the first time, it will be written by Tom Maguire -- a worthy successor to Michael Feeney.This new edition is updated to the Finance Act 2019. An extremely practical book, it features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your clients' tax liabilities as low as possible.

U.S. Investment Since the Tax Cuts and Jobs Act of 2017
U.S. Investment Since the Tax Cuts and Jobs Act of 2017

Author: Emanuel Kopp

Publisher: International Monetary Fund

Published: 2019-05-31

Total Pages: 37

ISBN-13: 1498317049

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There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.

Taxing Profit in a Global Economy
Taxing Profit in a Global Economy

Author: Michael P. Devereux

Publisher: Oxford University Press

Published: 2020-09-29

Total Pages: 401

ISBN-13: 0198808062

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The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.

Imposing Standards
Imposing Standards

Author: Martin Hearson

Publisher: Cornell University Press

Published: 2021-06-15

Total Pages: 162

ISBN-13: 1501755994

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In Imposing Standards, Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits on the ability of developing countries to tax businesses, denying the Global South access to much-needed revenue. The international rules that allow tax avoidance by multinational corporations have dominated political debate about international tax in the United States and Europe, especially since the global financial crisis of 2007–2008. Hearson asks how developing countries willingly gave up their right to tax foreign companies, charting their assimilation into an OECD-led regime from the days of early independence to the present day. Based on interviews with treaty negotiators, policymakers and lobbyists, as well as observation at intergovernmental meetings, archival research, and fieldwork in Africa and Asia, Imposing Standards shows that capacity constraints and imperfect negotiation strategies in developing countries were exploited by capital-exporting states, shielding multinationals from taxation and depriving nations in the Global South of revenue they both need and deserve. Thanks to generous funding from the Gates Foundation, the ebook editions of this book are available as Open Access volumes from Cornell Open (cornellpress.cornell.edu/cornell-open) and other repositories.

International Tax Policy and Double Tax Treaties
International Tax Policy and Double Tax Treaties

Author: Kevin Holmes

Publisher: IBFD

Published: 2007

Total Pages: 433

ISBN-13: 9087220235

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Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.