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The Foreign Tax Credit
Analysis of the basic structural elements of the foreign tax credit, indicating the theoretical concepts upon which the structure is built, and then appyling the knowledge of that structure to a consideration of the technical and often quite intricate details of implementation. The possible advantages and disadvantages of the foreign tax credit system are discussed.
Self-employment Tax
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U.S. Tax Treaties
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Corporate Income Taxes under Pressure
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
International Tax Policy and Double Tax Treaties
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
