Reorganization continuity of interest doctrine this portion of the introduction to the basic principles of united states federal income taxation of corporate acquisitions is part of the pillsbury winthrop shaw pittman llp tax page, a world wide web demonstration project. Browse the worlds largest ebookstore and start reading today on the web, tablet, phone, or ereader. And yet the international tax system clearly requires some allocation to be adopted, if the profits of multinational companies are to be taxed at all. This report describes the new international tax systemand its many gapsand also provides a road map for how to fix. The ibfd international tax glossary is regarded as an authoritative resource for defining tax and tax related terms by its thousands of users all over the world. Just months after the obama administration cracked down on mergers that helped u. Deloittes international tax professionals around the world deliver targeted support designed to guide companies through crossborder deals with an understanding of local culture and business environments. Taxes pfizer, the giant drugmaker, is the latest american company seeking a foreign merger to. Clarification of the meaning of beneficial owner in the oecd model tax convention response from ibfd research staff1 i introduction the research staff of the ibfd welcomes this opportunity to engage in a discussion with the oecd about the meaning of the term beneficial. An offshore financial center in tangier is open to all international banks and financial institutions that have. Anrechnung auslandische steuern crediting of foreign tax. It slashed taxes on corporate income, both domestic and foreign. Bpms client portal utilizes the highest benchmarks of online security and provides you a convenient and secure way to access your documents.
No 10 plays down tory idea to merge national insurance and. Through use of bpms secure web based portal, your electronic data and documents are instantly accessible from anywhere in the world. Ibfd international tax glossary, 7th edition why this book. Basic concepts and policy issues congressional research service 1 introduction recent deficit reduction and tax reform plans have included broad proposals to reform the u. Moreover, such costs are regressive to size, which means that they hit small and mediumsized enterprises harder than larger. Corporate taxation in an international context 431 there would seem to be no logical basis for dividing up these global profits between the three countries. The ruling dealt with the merger of two controlled foreign companies cfcs for purposes of s9d of the income tax act, no 58 of 1962 act. Luxembourg in international tax takes an indepth look at corporate taxation in luxembourg and the tax issues that may be of interest in an international environment.
Ibfd international tax glossary revised 6th edition editor. Intermediary holding companies and group taxation 309 to provide the group with structural flexibility of the groups assets. Thus, it would be desirable to have a clear intellectual framework on hand. Richard sackin is an advisor with over 30 years of experience in the fields of accounting and taxation. Table of contents introduction to the sixth edition v using the international tax glossary vii list of tax terms a to z 1 appendix i international organizations, treaties and tax related bodies 480. After the emphasis put on various international aspects of corporate income tax, including harmful tax competition, transfer pricing and taxation of ecommerce by the keynote speakers at previous two annual tax conferences of the asian development bank, i would like to discuss two trends in individual income tax in europe, the intro. This is followed by an outline of the system of group taxation and how group taxation would benefit the ihc group on the ihcs performance of its functions. Ibfd international tax glossary more than 2,000 fully searchable tax terms with explanations, including clear translations of over 400 key terms in french, german, spanish and dutch. Get your free access to the ibfd online tax glossary in two easy steps dec082016 the regularly updated ibfd international tax glossary is regarded by thousands of users all over the world as a handy, authoritative resource for defining tax and tax related terms. May, 2014 companies face backlash over foreign mergers to avoid u. Using the ibfd international tax glossary crossreferences crossreferences are used in the following ways. Egyptian income tax that may have been payable with respect to profits from works performed abroad, but without a thorough definition of terms.
Richard sackin cpa eisneramper accounting firm tax services. The international tax glossary is regarded as an authoritative resource for. For example, the target company or its owners may be subject to tax on the gain from an assets sale. No 10 plays down tory idea to merge national insurance and income tax. Cfos and other finance professionals who have some familiarity with tax and wish to increase their understanding of the area will also find it helpful. It is a wellknown fact that tax compliance costs for international and crossborder activities are substantial. The main international sources of tax law are bilateral or multilateral treaties, and one important source for the interpretation of treaties is the oecd model tax treaty and the accompanying commentary. Academic year 201516 international and european tax law. Understanding and fixing the new international corporate tax. International merger by foreign entanglements arthur r. Tax on tax the charging of tax on tax inclusive prices. Sep 20, 2016 if your institution is contemplating a merger, there are a variety of tax issues to consider. Ibfd international tax glossary, 7th edition book ibfd.
Outline sec filing requirements and tax considerations 18. Edition seventh revised edition editor, julie rogersglabush. If your organisation has done so you can log on here using the credentials provided to you by your organisation. The regularly updated ibfd international tax glossary is regarded by thousands of users all over the world as a handy, authoritative resource for defining tax and tax related terms. Swedish crossborder reorganisations lund university. Given that, we would be analysing the basics of us international tax system in this article.
Ibfd international tax glossary in searchworks catalog. Some organisations have joined ibfd in an identity federation. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear. Steuerrecht, internationales international tax law. Treatment of intercompany debt in a reorganization. Clarification of the meaning of beneficial owner in the. Wilson small and midsize companies are continuing to expand their businesses globally at an everincreasing rate. Rich has many years of experience handling tax structuring and due diligence for mergers and acquisitions of u. Accounting group interprets rules on postmerger nols, tax. Taxes pfizer, the giant drugmaker, is the latest american company seeking a foreign merger to elude u. Abatement a reduction in the assessment of tax, penalty or interest when it is. Banking, finance and accounting business corporate reorganizations accounting and auditing recognition of gain or loss taxation recognized gain or loss taxation tax accounting laws, regulations and rules tax administration. On september 22, 2014, the united states treasury issued notice 201452 the notice, which announces its intent to issue regulations that would i increase the effective tax rate to foreign acquirers of us targets by limiting the opportunities to achieve tax efficiencies in the course of integrating the operations, management.
Get your free access to the ibfd online tax glossary in two easy steps dec082016. Stanford libraries official online search tool for books, media, journals, databases, government documents and more. Cliffe dekker hofmeyr merger of controlled foreign companies. An analysis of alternative proposals for the reform of international tax, national tax journal, vol. For global tax practitioners that deal with crossborder tax issues in select countries, ibfd tax explorer country select enables you to customize your offering with the 10 countries that you want to focus on, providing a costefficient solution to your global tax needs. Ibfd international tax glossary top results of your surfing ibfd international tax glossary start download portable document format pdf and ebooks electronic books free online rating news 20162017 is books that can provide inspiration, insight, knowledge to the reader. Verschmelzung durch aufnahme merger by means of acquisition. The ministry of corporate affairs of the government of india mca by way of a notification 1 has notified section 234 2 of the companies act, 20 act enabling crossborder mergers with effect from april, 2017. The international tax handbook, 6th edition iberglobal. The tax cuts and jobs act tcja radically changed the international tax system. The ibfd international tax glossary is regarded as an authoritative resource for defining tax and taxrelated terms by its thousands of users all over the world.
This is the sixth edition of the international tax handbook that has been produced by. These proposals have raised concerns over how changing the. The usual valueadded tax vat is a general sales tax on all goods and services. It is levied at each stage of production and accumulates so that it is equivalent to a tax on all final.
International tax issues for small and midsize companies michael j. Explain the effect of merger on earnings per share and market price per share. Ibfd, your portal to crossborder tax expertise why this book. International tax brunei darussalam highlights 2012 pdf. Merger term generally used to describe a number of operations involving the reorganization of companies. In the early stages of global business expansion, companies may export products or provide services to customers in foreign markets. International taxation and multinational firm location decisions.
Authoritative resource for defining tax and tax related terms. Ebook ibfd international tax glossary as pdf download. A filing status claimed by married couples who wish to combine income and file a single tax return together in order to take advantage of various tax benefits. International tax international mergers and acquisitions. As a general rule, for tax purposes, the buyer prefers to purchase shares of stock or ownership interests, not assets, and the seller prefers the converse. Alternatively, regression 6 in the table includes interaction terms of the effective tax. This will facilitate the understanding of current issues such as where and how should income from international transactions be taxed, the problems of double taxation andtax avoidance by multinational corporations or the latest initiatives against tax havens. Basics of us international tax nishith desai associates. With the addition of hundreds of completely new and revised definitions, a new appendix outlining the various levels and locations of tax courts in 42 countries, as well as the expansion.