The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
This is the first monograph dedicated to the site of Socoh in the Judean Shephelah. Our research was initiated in 2010 as an intensive survey by the Institute of Archaeology, Southern Adventist University, and the Institute of Archaeology, The Hebrew University of Jerusalem. The study incorporates historical sources that are listed and analyzed, including the Bible, ancient Near Eastern, Byzantine, and Medieval records. A history of the research conducted over the past 190 years by explorers, geographers, and archaeologists is compiled, before providing the full report on the results of an intensive site survey conducted at Socoh in 2010. Finally, specialized studies of the finds and a report of recent salvage excavations of burial caves, looted by antiquity robbers nearby, give a state-of-the-art presentation of the latest information known about this important biblical site in southern Judah.
WTO Law and Direct Taxation are linked in numerous ways. The WTO Agreements, thereof especially the GATT and GATS Agreements, contain several explicit provisions on the subject of direct taxes or even on its delimitation from Tax Treaty Law. To some extent, the scope of application of WTO Law has been broadened by case law to comprise also direct taxes. This entails overlappings particularly with regard to the law of subsidies, prohibitions of discrimination, and most-favoured-nation obligations. This book highlights increasingly relevant interdependencies between WTO Law and Direct Taxation from the viewpoint of 21 States. Special emphasis is placed on the conformity of national taxes on profits with WTO Law as well as on specifics of interpretation in several Member States. 21 National Reports from nearly all EU countries as well as Colombia, Israel, New Zealand, Norway and the USA dealt with this topic and were compiled and published in this volume. Additionally, a General Report prepared by Servatius van Thiel summarises the results of the National Reports. Moreover, experts in this field joining the Conference among them Reuven Avi-Yonah, Michael Lennard and Raymond Luja have volunteered contributions dealing with specific problems of WTO and Direct Taxation.
The results of recent archaeological excavation, systematic rural survey and detailed studies of pottery distributions have revealed the extent and complexities of the economy in the eastern empire. The eight papers in this volume demonstrate this complexity and prosperity, examining several types of product and how the economy evolved over time. Contents: New Rome, new theories on Inter-regional exchange: East Mediterranean economy in Late Antiquity ( Sean Kingsley and Michael Decker ); Urban Economies of Late Antique Cyrenaica ( Andrew Wilson ); The economic impact of the Palestinian wine trade in Late Antiquity ( Sean Kingsley ); Food for an empire: wine and oil production in North Syria ( Michael Decker ); Beyond the amphora: non-ceramic evidence for Late Antique industry and trade ( Marlia Mundell Mango ); The economy of Late Antique Cyprus ( Tassos Papacostas ); LR2: a container for the military annona on the Danubian border? ( Olga Karagiorgou ); Specialization, trade and prosperity: an overview of the economy of the Late Antique Eastern Mediterranean ( Bryan Ward-Perkins ).
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
The Alien Tort Statute (also referred to as the Alien Tort Claims Act) is a US statute that provides a cause of action for violations of international law. While originally used against former dictators and military officials who fled to the U.S. after the respective governments in their home countries have been removed, human rights activists are now targeting transnational corporations or multinational enterprises for human rights violations in connection with their investments made outside the United States. This book examines and analyzes corporate liability under the Alien Tort Statute.
The Taxation of Trusts in South Africa is the first book to exclusively cover the direct and indirect taxation of trusts in South Africa, including a look at the application of the exchange control regulations to both onshore and offshore trusts.
Proposes a reconstruction of the Temple, which differs from conventional descriptions in Jewish literary sources during the First and Second Temple eras. This book examines the individual descriptions of the Temple and considers the influence of the descriptions on subsequent ones.
This paper assesses the landmark Tax Cuts and Jobs Act (TCJA), from the perspective of both the U.S. itself and the wider world. The reform has many positive aspects including steps to broaden the base of, and reduce marginal rates under, the personal income tax (PIT), reduce distortions to investment and financing decisions, and mitigate outward profit shifting. But the TCJA has a large fiscal price tag and leaves significant uncertainty as to how the U.S. tax system will develop. The PIT changes could have better targeted relief at low earners, and there is scope to more fully address distortions in business taxation. The novel international provisions create a complex array of both positive and negative international spillovers, and have the potential to significantly reshape the wider international tax system.
These volumes comprise a collection of papers by Michael E. Stone, written over a period of 35 years. Stone is a leading scholar in two different fields of research, the Jewish literature of the Second Temple period including the Dead Sea Scrolls, and Armenian Studies. So this collection includes essays relating to the origins and nature of the Apocryphal literature and its relationship with the Dead Sea Scrolls, as well as more specific studies devoted to themes that have interested Stone throughout his career, including Messianism, 4 Ezra, Adam and Eve, and Aramaic Levi Document. His Armenian interests have embraced the Armenian Biblical text, Armenian pilgrimage to and presence in the Holy Land and Armenian paleography and epigraphy. Papers included in the volumes, some of which were originally published in obscure venues, touch on all these themes. A number of previously unpublished papers are included.
The World and the Word is a fresh introduction to the Old Testament driven largely by the fact that so much Christian preaching and teaching today increasingly ignores what is eighty percent of the Bible. Authors Eugene Merrill, Mark Rooker, and Michael Grisanti work through the world and text of the Old Testament always making three major points: • The Old Testament is a rich source of theology and doctrine that is presupposed by the New Testament. Without it, Christian theology would be seriously deficient. • Mastery of the Old Testament is crucial to an understanding of the New Testament. • The Old Testament offers, by teaching and example, practical principles of belief and behavior for contemporary times. Who God was and what He did then can be replicated in the lives of men and women today. Separating the verifiable biblical and extra-biblical data from the various interpretations of that same information, the book further shows how the Old Testament forms the platform and matrix from which sprang the life, ministry, and teachings of Jesus and the church. The World and the Word will help students see an entry point into the very heart and design of God who loves them and wishes to make them the special object of His grace.
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