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For purposes of relieving double taxation, the payment of United States income tax is made in the form of a foreign tax credit. (...) The tax conventions based on the Organisation for Economic Cooperation and Development (OECD) model tax convention provide that taxpayers subject to double taxation may choose between a tax credit and a deduction to relieve the effects of double taxation. (...) For the purpose of relieving the effects of double taxation, the payment to settle the United States income tax obligation is made by means of a foreign tax credit.
Language:English
Score: 1057950.5 - www.un.org/en/internalj...t/judgments/2012-unat-240e.pdf
Data Source: oaj
Two Basic Types of Double Taxation Developing effective methods for avoiding double taxation requires an understanding of the circumstances under which double taxation arises and the principal mechanisms governments use to avoid double taxation. There are two basic types of double taxation and two basic conceptual mechanisms for avoiding double taxation. The first type of double taxation is often called “economic double taxation.”
Language:English
Score: 1038198.9 - https://www.itu.int/ITU-D/fina...uale_Varley-Contribution-e.pdf
Data Source: un
Regional telecommunications Taxation Issues (cont’d) • These taxes may be passed on to consumers in the Caribbean region by the common carriers. • Taxation impacts the affordability of telecommunications in the Region. Recommendations • Regional governments should collaborate more closely on telecommunications taxation matters. • Cross-Border taxation is a matter for States to agree upon in trade agreements and should not be left to the sole discretion of commercial interest groups. • The WCIT recommendation should be considered by regional governments. (...) Thank You Slide Number 1 CONTENTS Taxation Rules – Customs Duties Taxation Rules - Other Universal Service Contribution - Proposed Selection of Taxes in Region, 2012 Regional Telecommunications Taxation Issues Regional telecommunications Taxation Issues (cont’d) Recommendations Slide Number 10
Language:English
Score: 1032268.3 - https://www.itu.int/ITU-D/fina...f/Sess7-3_Cynthia_Trinidad.pdf
Data Source: un
Agenda ITU | Telecommunication Development Bureau (BDT) / Telecommunication Standardization Bureau (TSB) ITU WORKSHOP ON TAXATION OF TELECOMMUNICATION SERVICES AND RELATED PRODUCTS ITU Headquarters Geneva, Switzerland 1-2 September 2011 PROGRAMME Day 1 - Thursday, 1 September 08.30 – 09.30 Delegate registration 09.30 – 09.45 Opening Ceremony 09.45 – 10.45 Session 1: Telecommunication service taxation: Understanding the process • Current situation – taxation practices • Services frequently taxed by Governments • Taxation on devices and handsets • Characteristics of the different types of taxation by service • Double taxation Martin Cave London School of Economics 10.45 – 11.00 Coffee break 11.00 – 12.30 Session 2: Presentations from countries and associations Moderator: Mr. (...) Pauline Tsafak 12.30 – 14.00 Lunch 14.00 -15.30 Session 3: The impact of taxation on ICT growth • Sectoral and Macro effects • Impact on penetration and affordability • Taxation policies and national ICT objectives • Policy and regulation implications Martin Cave – Windfred Mfuh London School of Economics 15.30 – 15.45 Coffee break 15.45 – 17.00 Panel discussion with the participation of Policy-Makers, Regulators, Associations and all ICT Stakeholders Moderator: BDT/TSB • What is the current situation and impact on ICT growth? (...) • What are the effects of taxation on competition? ITU | Telecommunication Development Bureau (BDT) / Telecommunication Standardization Bureau (TSB) Day 2 - Friday 2 September 09.30 – 10.45 Session 4: International double taxation of telecommunications services • Techniques that Governments use to avoid imposing double taxationTaxation in the framework of the International Telecommunication Regulations ITRs Paul DePasquale and Alyssa Varley Baker & McKenzie, Switzerland 10.45 – 11.00 Coffee break 11.00 – 12.30 Session 5: Presentations from countries and associations Moderator: Mr.
Language:English
Score: 1027004.7 - https://www.itu.int/ITU-D/fina...Geneva_Taxation/pdf/Agenda.pdf
Data Source: un
Folie 1 ©2011 Baker & McKenzie Zurich Telecommunications & Methods for Avoiding Double Taxation ITU Workshop Geneva, Switzerland 2 September 2011 Paul DePasquale and Alyssa Varley Baker & McKenzie Zurich bakermckenzie.com Overview 1. The Melbourne Agreement 2. Double Taxation in General 3. Avoiding Double State Taxation in the United States Context 4. (...) [change title in View/Header and Footer] 7 Double Taxation in General bakermckenzie.com Basic Types of Double Taxation ● Economic Double Taxation – Two different persons are subject to tax on the same income or capital ● Juridical Double Taxation – One person is subject to tax on the same income or capital by more than one tax authority – Three possible situations bakermckenzie.com Mechanisms for Avoiding Double Taxation ● Exemption Method – Concept: the residence jurisdiction does not tax income that the source jurisdiction may tax – Types: full exemption and progressive exemption ● Credit Method – Concept: the residence state taxes total worldwide income of a taxpayer resident in that state but will allow a credit for taxes paid to the source state – Types: full credit and ordinary credit bakermckenzie.com Mechanisms for Avoiding Double Taxation Exemption Method Example: Company has $100 of income; $70 from Residence Country and $30 from Source Country.
Language:English
Score: 1026802.3 - https://www.itu.int/ITU-D/fina...Taxation/pdf/dePasquale-en.pdf
Data Source: un
Economy Investments: Revised UN convention seeks to prevent double taxation NEWS - AFRICA NEWS New York, US - The UN said it has updated a set of guidelines to prevent double taxation between countries, as well as to avoid tax evasion which costs countries US$3.1 trillion every year, in order to promote investments. (...) NEW YORK, USA -- The United Nations announced on Wednesday that it has updated a set of guidelines to prevent double taxation between countries, as well as to avoid tax evasion, which costs countries $3.1 trillion every year. http://www.afriquejet.com/economy-investments-revised-un-convention-seeks-to-prevent-double-taxation-2012031535071.html http://www.un.org/russian/news/fullstorynews.asp? (...) UN updates convention on double taxation to spur investment in developing nations Balita UNITED NATIONS, March 15 — The United Nations will launch an updated model of the convention on double taxation to help less developed countries benefit more from international investments, officials from the UN Committee of Experts on International Cooperation in Tax Matters said here Wednesday.
Language:English
Score: 1026802.3 - https://www.un.org/esa/ffd/wp-.../10/ICTM2012_PressCoverage.pdf
Data Source: un
He is the co-editor of the Bulletin for International Taxation and the principal author (with Hugh J. Ault) of “Comparative Income Taxation: A Structural Analysis”, 3 rd edition, published by Kluwer in 2010. (...) In Australia, he has worked as a consultant on projects for the Australian Treasury, the Board of Taxation, the Australian National Audit Office and the Australian Taxation Office. (...) He has also given lectures on international tax issues in seminars and teaches the international taxation module of UNESCPA´s Masters in Taxation Alvaro C.
Language:English
Score: 1026802.3 - https://www.un.org/esa/ffd/wp-...015/07/2015PTB_Biographies.pdf
Data Source: un
Why does taxation of capital gains earned by nonresidents matter – and how can failure to tax capital gains contribute to tax base erosion? (...) 2 2 Impact of Capital Gains Taxation Conversion: Taxpayers can frequently transform the income from property into capital gains. (...) Options for taxation of capital gains include: • No taxation of capital gains • No taxation of capital gains of nonresidents • Exception from taxation of capital gains for certain assets (e.g., home) • Special rate available for capital gains meeting specified requirements • Taxing capital gains as part of regular income tax • Taxing capital gains under a separate tax • Taxing gains as capital or ordinary depending on the use of the asset by the taxpayer • Deemed gains taxed on transfer by gift, at death, or on transfer out of the country 6 4 Tax Treatment of Capital Gains Domestic Taxation: – Source of Capital Gains: General Approach: A broad but not universally implemented principle is that capital gains should be taxed (as having source) in the same country that would claim source taxation over the income from the asset. – Examples of the concept: • Rental income v. gain on sale of the rental property • Royalty income v. gain on the sale of the patent • Dividend income v. gain on the sale of the stock 7 Tax Treatment of Capital Gains Domestic Taxation: – Source of Capital Gains: – Inconsistent application of the source principle: Sometimes the source principle is invoked to justify taxation and sometimes taxation does not follow the principle.
Language:English
Score: 1026345.9 - https://www.un.org/esa/ffd/wp-...esidents_CapitalGains_Ring.pdf
Data Source: un
Taxation and land markets 1 Taxation and land markets Simon KEITH MA FRICS IRRV formerly Assistant Chief Valuer in UK Inland Revenue Valuation Office, Senior Officer Land Tenure Service in FAO Purposes of this session • Identify all taxes that might impact on property markets • Identify how each tax might effect property markets • examine three common distortionary factors 2 Some general comments on taxation • A statement of the obvious! The main purpose of taxation is revenue generation • Taxation administration is a harsh discipline • Anything to do with taxation is highly political • Tax administrators dislike ‘exemptions’ Taxation and social engineering • Many examples of taxation being used negatively to discourage activities. • Taxes on alcohol and tobacco • High taxes sometimes designed to redistribute wealth • Fewer successful examples of positive effects from taxation 3 What to look for • What is the rate of tax? (...) • Taxation in your country. Have you any examples of taxation being successfully used as an incentive?
Language:English
Score: 1022755.6 - https://www.fao.org/fileadmin/...cuments/LANDNET/2012/07_en.pdf
Data Source: un
When multiple jurisdictions impose separate and sometimes conflicting tax rules, cross-border activities can be subject to double taxation. The principal mechanisms for avoiding double taxation are (i) to exempt the income from taxation in one or more jurisdictions (the "exemption method") or (ii) to allow double taxation but permit the taxpayer to claim a credit or deduction for taxes paid in one jurisdiction against his or her tax liability in another jurisdiction (the "credit method"). . This paper provides a brief overview of the mechanisms governments use for avoiding double taxation. After a brief discussion of the current treatment of the joint provision of international wireless telecommunications services under the International Telecommunications Regulations (“ITRs”), we discuss the principal mechanisms for avoiding double taxation and principal variations for each method. Finally, we illustrate the U.S. experience in mitigating state-level double taxation on telecommunications services.
Language:English
Score: 1021941.3 - https://www.itu.int/ITU-D/fina...DePasquale-Varley_Abstract.pdf
Data Source: un