Unitary Tax

Unitary Tax

Author: United States. Congress. Senate. Committee on Foreign Relations. Subcommittee on International Economic Policy

Publisher:

Published: 1985

Total Pages: 456

ISBN-13:

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Transfer Pricing and the Arm's Length Principle in International Tax Law

Transfer Pricing and the Arm's Length Principle in International Tax Law

Author: Jens Wittendorff

Publisher: Kluwer Law International B.V.

Published: 2010-01-01

Total Pages: 914

ISBN-13: 9041132708

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The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.


Financing State and Local Governments

Financing State and Local Governments

Author: J. Richard Aronson

Publisher: Brookings Institution Press

Published: 2010-12-01

Total Pages: 298

ISBN-13: 9780815716273

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State and local governments are at a financial crossroads. As the federal government attempts to reduce its deficits, state governments will have to provide a greater share of support for mandatory social programs. Local governments face demands for new initiatives in education and for civic improvements. Both have obligations to employee pension plans that are large and still relatively untested. Running counter to these claims on state and local budgets is a voter effort to limit the amounts that governments may tax or spend. This fourth edition of James A. Maxwell's classic and widely acclaimed book will help both layman and lawmaker understand the choices open to their governments. It provides a lucid, nontechnical analysis of state and local finance. It gives concise descriptions of the taxes, grants, debt issues, and user charges that finance state and local government and discusses their relative virtues and drawbacks. It traces the history of state and local finance and presents statistical data on expenditures, federal aid, revenue from taxes and user charges, debt, and pension funds. The new edition, in recognition of changes since the mid-1970s, also includes a separate chapter on financing education and broadened analyses of federal grant programs, employee retirement systems, and nonguaranteed municipal debt.