Results 251 to 260 of about 204,046 (312)
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Tax Treaty Entitlement

2015
This book takes a timely and detailed look at crucial areas concerning the entitlement to tax treaties.
Pistone P.   +4 more
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Tax Treaty News

Bulletin for International Taxation, 2009
The author, in this “Tax Treaty News”, considers various recent Belgian, Canadian and US treaty cases of note, as well as commenting on the October 2010 meeting of the UN Committee of Experts on International Cooperation in Tax Matters regarding the anticipated 2011 UN Model Tax Convention.
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Tax Treaty Disputes in Italy

SSRN Electronic Journal, 2017
This introductory section outlines the situation in Italy in relation to the legal standing of tax treaty law under the Italian constitutional system, and the treaty-making process. In the Italian constitutional system tax treaties are written conventions made by Italy with other sovereign States persons with international legal capacity, which contain
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Expatriation Tax – Renouncing a Tax Treaty

SSRN Electronic Journal, 2012
In this article, the author considers the implications of the various US expatriation tax regimes that have been enacted over the years, with special emphasis on renouncing a tax treaty. The author also suggests possible improvements to the current US expatriation regime.
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Beneficial Ownership in Tax Law and Tax Treaties

2020
This book explores the concept of beneficial ownership in equity law, the domestic tax laws of the United Kingdom, Canada and the United States, as well as its varied and increasing uses in international tax law. By analysing the evolution of beneficiary rights in equity and the use of beneficial ownership wording in tax law, the book draws a roadmap ...
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International Tax Treaties

2013
Diplomatic ties between China and Brazil officially started in 1974 with the establishment of diplomatic embassies in each country’s capital. In 2010, the second BRIC summit was held in Brazil and was attended by China’s President Hu. During the meeting, proposals were made for increased cooperation between Brazil and China on political and trade ...
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European VAT and Tax Treaties

2011
The article examines the interrelation between European VAT and tax treaties.
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Causality under Tax Treaties

Intertax, 2016
This article examines the concept of causality, a somewhat underexposed aspect of categorizing income under the distributive rules of tax treaties. The author gives his views on causality under tax treaties, and suggests a method of approaching this concept.
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Tax Treaty Arbitration

2020
Pistone P.   +6 more
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The International Tax Treaty

2016
This chapter describes and explains how tax treaties operate in cross-border transactions. The situs of an international investment is often determined by the existence of a low tax, reducing a tax treaty in force. However, careful examination must be made as several countries have adopted anti-tax-treaty provisions to challenge treaty benefits to some
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