Global Perspectives on Income Taxation Law

ISBN-10: 0195321367
ISBN-13: 9780195321364
Edition: 2011
List price: $29.95
30 day, 100% satisfaction guarantee

If an item you ordered from TextbookRush does not meet your expectations due to an error on our part, simply fill out a return request and then return it by mail within 30 days of ordering it for a full refund of item cost.

Learn more about our returns policy

what's this?
Rush Rewards U
Members Receive:
coins
coins
You have reached 400 XP and carrot coins. That is the daily max!
You could win $10,000

Get an entry for every item you buy, rent, or sell.

Study Briefs

Limited time offer: Get the first one free! (?)

All the information you need in one place! Each Study Brief is a summary of one specific subject; facts, figures, and explanations to help you learn faster.

Add to cart
Study Briefs
Careers in Legal Assisting Online content $4.95 $1.99
Add to cart
Study Briefs
SQL Online content $4.95 $1.99
Add to cart
Study Briefs
MS Excel® 2010 Online content $4.95 $1.99
Add to cart
Study Briefs
MS Word® 2010 Online content $4.95 $1.99

Customers also bought

Loading
Loading
Loading
Loading
Loading
Loading
Loading
Loading
Loading
Loading

Book details

List price: $29.95
Copyright year: 2011
Publisher: Oxford University Press, Incorporated
Publication date: 3/2/2011
Binding: Paperback
Pages: 202
Size: 6.00" wide x 9.00" long x 0.50" tall
Weight: 0.682
Language: English

Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the International Tax LLM Program at the University of Michigan Law School. He teaches the basic course on taxation and courses on international taxation, corporate taxation, tax treaties and transnational law. He is currently a member of the Steering Group of the OECD International Network for Tax Research and Chair of the ABA Tax Section Tax Policy Committee, an International Research Fellow of the Oxford University Centre for Business Taxation, and a Trustee of the American Tax Policy Institute. From 1989 to 1993, Prof. Avi-Yonah practiced tax law in Boston and New York, specializing in the international tax aspects of mergers and acquisitions. From 1994 to 2000 he was Assistant Professor of Law at Harvard Law School. He has served as consultant to the U.S. Treasury and the OECD on tax competition issues, and has been a member of the executive committee of the New York State Bar Association Tax Section and of the Advisory Board of Tax Management, Inc. He has published numerous articles on domestic and international tax issues, and is the author of International Tax as International Law: U.S. Tax Law and the International Tax Regime (Cambridge Univ. Press, 2007) and U.S. International Taxation: Cases and Materials (Foundation Press, 2nd ed. 2005, with Brauner & Ring), and co-editor of Comparative Fiscal Federalism: Comparing the U.S. Supreme Court and European Court of Justice Tax Jurisprudence (Kluwer, 2007). Prof. Avi-Yonah graduated summa cum laude from the Hebrew University in 1983, received a PhD in History from Harvard University in 1986, and received a JD magna cum laude from Harvard Law School in 1989. Nicola Sartori is a lecturer in "Comparative Law and Economics of Taxation" at the International University College of Turin, Italy and also holds a temporary chair in "International and Comparative Taxation" at the University of Modena Law School, Italy. She holds a degree in Law and Business Administration, summa cum laude, from Bocconi University, Milan, a Ph.D in Tax Law from the University of Milan - Bicocca, and a LL.M. in International Taxation and a S.J.D. from the University of Michigan Law School. Omri Marian practices tax law at the New York Office of Sullivan & Cromwell LLP. He holds a degree in Law and Political Science, magna cum laude, from Tel Aviv University, Tel Aviv, Israel, and an LL.M. in International Taxation and an S.J.D., from the University of Michigan Law School, Ann-Arbor, Michigan.

Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the International Tax LLM Program at the University of Michigan Law School. He teaches the basic course on taxation and courses on international taxation, corporate taxation, tax treaties and transnational law. He has published numerous articles on domestic and international tax issues, and is the author of International Tax as International Law: U.S. Tax Law and the International Tax Regime (Cambridge Univ. Press, 2007) and U.S. International Taxation: Cases and Materials (Foundation Press, 2nd ed. 2005, with Brauner & Ring), and co-editor of Comparative Fiscal Federalism: Comparing the U.S. Supreme Court and European Court of Justice Tax Jurisprudence (Kluwer, 2007). Prof. Avi-Yonah graduated summa cum laude from the Hebrew University in 1983, received a PhD in History from Harvard University in 1986, and received a JD magna cum laude from Harvard Law School in 1989. From 1989 to 1993, Prof. Avi-Yonah practiced tax law in Boston and New York, specializing in the international tax aspects of mergers and acquisitions. From 1994 to 2000 he was Assistant Professor of Law at Harvard Law School. He has served as consultant to the U.S. Treasury and the OECD on tax competition issues, and has been a member of the executive committee of the New York State Bar Association Tax Section and of the Advisory Board of Tax Management, Inc. He is currently a member of the Steering Group of the OECD International Network for Tax Research and Chair of the ABA Tax Section Tax Policy Committee, an International Research Fellow of the Oxford University Centre for Business Taxation, and a Trustee of the American Tax Policy Institute. Nicola Sartori holds a temporary chair in "International and comparative taxation" at the University of Modena Law School, Italy, and is also in "Comparative law and economics of taxation" at the International University College of Turin, Italy. He holds a degree in Law and Business Administration, summa cum laude, from Bocconi University, Milan, a Ph.D in Tax Law from the University of Milan - Bicocca, and a LL.M. in International Taxation and a S.J.D. from the University of Michigan Law School. Omri Marian practices tax law at the New York Office of Sullivan & Cromwell LLP. He holds a degree in Law and Political Science, magna cum laude, from Tel Aviv University, Tel Aviv, Israel, and an LL.M. in International Taxation and an S.J.D., from the University of Michigan Law School, Ann-Arbor, Michigan.

Preface
Foreword
Introduction
Some Theoretical Aspects of "Comparative Taxation"
What is comparative taxation?
Some possible approaches to the study of comparative tax law
The functional approach to comparative tax studies
Comparative tax law as a study of cultural differences
The critical approach to comparative tax studies
Comparative tax study as an exercise in economic analysis
The economic principles of taxation: efficiency, equity, and simplicity
What to expect next
Taxable Income
Taxable income definition: global vs. schedular and source VS. accretion
Taxation of fringe benefits
Imputed income from owner-occupied housing
Wmdfalls
Damage awards
Taxation of damage awards
The treatment of damage awards
The issue of deferred damage compensation
Which "damages" receive favorable treatment? physical? mental? reputation?
Cancellation of indebtedness
Inclusion of debt relief in gross income
Exceptions to inclusion
Gifts and bequests
Commercial gifts
The realization requirement
Deductions
Business expenses
Commuting, clothing, and other nondeductible expenses
Commuting
Oothing
Child care costs
Travel and entertainment
Business entertainment
Business travel
Capital expenditures
Depreciation
Business interest
Losses
Capital losses
Other loss limitations
Personal expenses
Apportionment of personal/business expenses
Medical expenses
Charitable contributions
Home mortgage and other personal interest
The Taxpaying Unit
Introduction
The basic issue and the two main models: how should we define taxable units? individual vs. family taxation
Concrete examples of countries adopting the individual model
Concrete examples of countries adopting hybrid solutions
Concrete example of a country adopting the family model
Anti-assignment of income rules
The reason for anti-assignment of income rules
The solutions adopted by some industrialized countries: examples
Tax Accounting
The taxable period and the accounting period: generaldefirritions
Definitions, main issues, and possible solutions
The solutions adopted by some countries: examples
Cash model versus accrual model
The accounting methods: cash versus accrual
The solutions adopted by some countries: examples
Net operating losses
Main issue and possible solutions
The solutions adopted by some countries: examples
Taxation of Capital Gains and Losses
General definitions: capital gain and losses, realization, basis
Definition of capital gain or loss
The concept of realization and recognition
The concepts of "basis" (or fiscal value) and "amount realized"
Nonrecognition transaction and exemption transactions
Nonrecognition transactions
Examples of concrete policy choices
Taxation of capital gains and capital losses: ordinary Income vs. separate income
Tax Avoidance
General definitions: tax evasion, tax avoidance, and licit tax savings
Substance over form (the experience of common law countries)
Abuse of law (the experience of civil law countries)
Hybrid solutions
Selected Business Tax Issues
Introduction
The definition of a business entity for tax purposes
The importance of entity classification for tax purposes in the study of tax convergence
Corporate entity definitions for tax purposes: examples from the G7 countries
Canada
France
Germany
Italy
Japan
United Kingdom
United States
Summary
Conventional determinants of corporate residency
Characterizing "real seat" of a corporate entity in the G7
Summary
Corporate tax rates
Some general remarks on corporate tax base
Corporate/shareholders tax: integration of distributed profits
Definition of integration and general issues
Some specific integration methods adopted by countries
Selected International Tax Issues
The basic distinction: global jurisdiction model vs. territorial jurisdiction model
Definition of residence and source
The two principles of international taxation: the single tax principle and the benefits principle
Outbound transactions
International tax rules that prevent double taxation
International tax rules that prevent double nontaxation
Inbound transactions
Tax treaty models: OECD, UN, and U.S. models
Conclusion
Index

×
Free shipping on orders over $35*

*A minimum purchase of $35 is required. Shipping is provided via FedEx SmartPost® and FedEx Express Saver®. Average delivery time is 1 – 5 business days, but is not guaranteed in that timeframe. Also allow 1 - 2 days for processing. Free shipping is eligible only in the continental United States and excludes Hawaii, Alaska and Puerto Rico. FedEx service marks used by permission."Marketplace" orders are not eligible for free or discounted shipping.

Learn more about the TextbookRush Marketplace.

×