IBFD International Tax Glossary. Front Cover · International Bureau of Fiscal Documentation. IBFD, – Taxation – pages. Get this from a library! IBFD international tax glossary. [Julie Rogers-Glabush;]. international tax glossary by Julie Rogers-Glabush · IBFD international tax glossary. by Julie Rogers-Glabush; International Bureau of Fiscal Documentation ;.

Author: Kagarg Kabei
Country: Mongolia
Language: English (Spanish)
Genre: Life
Published (Last): 1 May 2017
Pages: 212
PDF File Size: 13.80 Mb
ePub File Size: 16.35 Mb
ISBN: 291-4-62634-251-6
Downloads: 79059
Price: Free* [*Free Regsitration Required]
Uploader: Vigul

Forms are often provided by the tax authorities for this purpose.

Criminal penalties, on the other hand, are enforceable only gloasary prosecution. It is often discussed as an alternative to the progressive tax. The taxpayer recipient is entitled to credit the tax withheld at source against his final tax liabilities determined by domestic tax law of the country in which he is resident.

SearchWorks Catalog

The discount is calculated automatically in your shopping cart. The portfolio interest exemption does not apply to bank loans made in the ordinary course of business.

Usually a combination of property, payroll, turnover, capital invested, manufacturing costs, etc. The CA is generally indicated in the definitions sections of tax treaties. Substance over form doctrine.

Upon exercising an option for separate taxation, a husband and wife are treated as separate individuals for the purpose of computing income tax.

Formats and Editions of IBFD international tax glossary. []

Base companies itnernational on certain activities on behalf of related companies in high-tax countries e. Would you also like to submit a review for this item? An LLC may be taxed as a partnership or a corporation depending on the nature of the status under which it is organized. Common stock is usually last in priority when profits or assets are distributed. As we value your opinion, we invite you internatiojal share your thoughts about this IBFD book with other clients.


Centre for Tax Policy and Administration

Abbreviations and bibliographical references to aid further research. Income is effectively connected if it is derived from assets which are used in or held for use in the US, and the activities of the US business were a material factor in the realization of the income.

Remember me on this computer. A variety of criteria, including share ownership ratio, may be ibf to determine whether one company is a subsidiary of another company for tax purposes.

Or portfolio of securities held by an investment company on behalf of investors. Please choose whether or not you want other users to be able to see on your profile that this library is a favorite of yours. This is a theoretical concept and no country uses it. Itnernational, formatting rules can vary widely between applications and fields of interest or tx.

The individual proprietor has the right to all the profits from the business and also the responsibility for all its liabilities. Information may only be used for tax purposes in the receiving country and it must be kept confidential, i. Generally speaking, two approaches are taken to foreign tax relief, i. This structure has the effect of averaging out the rate of foreign tax paid. Rather, it is a return of the shareholder’s investment in the stock of the company. Its website is www.

Artificial schemes lgossary create circumstances under which no tax or minimal tax is levied may be disregarded if they do not serve a “business purpose”. Broadly speaking, it refers to the highest level of control of the business of a company. It is not a separate legal entity.

It refers to interjational period of time a taxpayer spends in each country. Such a distribution would constitute a taxable dividend to the shareholder to the extent of current and accumulated earnings and profit under US tax law. An essential feature of such regimes is that they attribute a proportion of the income sheltered in such companies to the shareholder resident in the country concerned. The specific requirements or preferences of your reviewing publisher, classroom teacher, institution or organization internationzl be applied.


We’ve updated our Terms and Conditions. The protocol may be signed simultaneously with the tax treaty or later, and it clarifies, implements or modifies treaty provisions. The E-mail Address es you entered is are not in a valid format.

Cookies are set by this site. The shareholders are generally liable only to the extent of the nominal value of their shares. Legal title to the trust property is vested in the trustee, while equitable title belongs to the beneficiaries.

A prison sentence may be imposed for serious tax fraud.

IBFD International Tax Glossary – International Bureau of Fiscal Documentation – Google Books

The rates of ibtd tax are frequently reduced by tax treaties. The formula equally glosssry the payroll factor, property factor, and sales factor. There are legal reserves which may be required by company law and may be necessary before dividends are distributed. In the second stage, any residual profit or loss remaining after the first stage division would be allocated among the parties based on an analysis of the facts and circumstances that might indicate how this residual would have been divided between independent enterprises.