2018) Sheppard, Hale E., Esq., What Constitutes a “Willful” FBAR Violation?, 129 J. TAX'N 24 (Nov. 2018) Sheppard, Hale E., Alarming U.S. Tax Rules And Information-Reporting Duties For Foreign Retirement Plans: Problems And Solutions, ...
本书介绍了国际税收概览、国际税法原则、避免双重征税税收协定范本、国内税收制度的影响、反避税措施等内容。
This publication considers the interpretation of tax treaties primarily from the standpoint of public international law.
Rent-a-star – the object and purpose of Article 17(2) Also in 2002, the author published together with Harald Grams an article about the historical development of Article 17(2) and the excessive taxation that results from the reversal ...
This report may be considered the basic document on which double taxation conventions have been built for decades. See also 6. g. ... See for further discussion: Kemmeren, Principle of Origin in Tax Conventions (2001), pp. 12-14. 8.
The reports contained in this book address two questions.
The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of ...
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures.
This book aims at identifying and clarifying the most common issues emerging in the interpretation of multilingual tax treaties.
International Tax Law