Advanced Introduction to International Tax Law

Paperback

Advanced Introduction to International Tax Law

Second Edition

2nd edition

9781788978507 Edward Elgar Publishing
Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law, Michigan Law School, University of Michigan, US
Publication Date: 2019 ISBN: 978 1 78897 850 7 Extent: 192 pp
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.

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Elgar Advanced Introductions are stimulating and thoughtful introductions to major fields in the social sciences, business and law, expertly written by the world’s leading scholars. Designed to be accessible yet rigorous, they offer concise and lucid surveys of the substantive and policy issues associated with discrete subject areas.

This second edition of the Advanced Introduction to International Tax Law provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax.

This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.

New to this edition:
• New material on the OECD Base Erosion and Profit Shifting (BEPS) project

• Coverage of the EU’s Anti Tax Avoidance Package

• Analysis of the US Tax Cuts and Jobs Act.

Key features include:
• defines and discusses the main types of jurisdiction to tax

• explains in depth both inbound and outbound taxation on both passive and active income

• delineates the source of income that is crucial for taxing non-residents and foreign tax credit

• discussion of transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source

• explains how the above elements are influenced by tax treaties and looks at the future of the international tax regime.

Composed of concise but insightful chapters, this revised second edition will prove to be a key resource for students of international tax law, as well as for scholars within the fields of tax law, international business law and international commercial law.
Contents
Contents: Part I: Overview of the International Tax Regime 1. Introduction: The International Tax Regime 2. Jurisdiction to Tax and Definitions 3. The Source Rules 4. Inbound Taxation: Passive Income 5. Inbound Taxation: Active Income 6. Transfer Pricing 7. Outbound Taxation: Passive Income 8. Outbound Taxation: Active Income 9. The Tax Treaty Network Part II: Selected Contemporary Issues 10. Three Steps Forward, One Step Back? Reflections on “Google Taxes” and the Destination-Based Corporate Tax 11. Evaluating BEPS 12. BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition? 13. Full Circle? The Single Tax Principle, BEPS, and the New US Model 14. A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits Index


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