ONE COURAGEOUS TAXATION CONVERSATION a Preparation Guide
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Chapter 5 Foreign Tax Credit P.302 Structural Tax Options for an Outbound U.S
Chapter 5 Foreign Tax Credit p.302 Structural tax options for an outbound U.S. enterprise in (1) foreign destination country and (2) any conduit country: 1) Branch (e.g., a disregarded entity) - current U.S. income taxation on profits & loss deduction availability in the U.S. 2) Foreign corporate subsidiary - income tax deferral of U.S. income tax & no possible U.S. loss utilization Is the entity decision controlled by (1) tax planning or (2) non-tax business considerations? 4/9/2013 (c) William P. Streng 1 Mitigating Possible Double National Level Taxation Possible double taxation exposure exists (1) since the U.S. income tax is imposed on a worldwide basis & (2) assuming foreign country income tax. Options for unilateral relief (as provided by U.S.): 1) a tax deduction for the foreign tax paid (not completely eliminating double taxation) 2) a (limited) credit for the foreign tax paid (primarily used by U.S.); limited to offsetting U.S. tax on taxpayer’s foreign income. 3) exemption under a territorial system (only 4/9/2013source country taxation)(c) William P. Strengand not in U.S. 2 Bilateral (i.e., Income Tax Treaty) Relief p.306 Double tax relief accomplished under a U.S. bilateral income tax treaty. See U.S. Model, Article 23 (2006). - possible shifting of the primary income tax liability from source location to residence jurisdiction. - but, a U.S. income tax treaty does include a “savings clause” - enabling the continuing worldwide tax jurisdiction of U.S. citizens, residents or corporations. 4/9/2013 (c) William P. -
History of the Jews Vol. V
History of the Jews Vol. V By Heinrich Graetz HISTORY OF THE JEWS CHAPTER I CHMIELNICKI AND THE PERSECUTION OF THE JEWS OF POLAND BY THE COSSACKS Condition of the Jews in Poland before the Outbreak of Persecution— Influence of the Jesuits—Characteristics of Poles and Jews—The Home of the Cossacks—Repression of the Cossacks by the Government—Jews appointed as Tax Farmers—Jurisdiction of the Synods—The Study of the Talmud in Poland—Hebrew Literature in that Country becomes entirely Rabbinical—Character of Polish Judaism—Jews and Cossacks— Chmielnicki—Sufferings of the Jews in consequence of his Successes—The Tartar Haidamaks—Fearful Massacres in Nemirov, Tulczyn, and Homel— Prince Vishnioviecki—Massacres at Polonnoie, Lemberg, Narol, and in other Towns—John Casimir—Lipmann Heller and Sabbataï Cohen—Renewal of the War between Cossacks and Poles—Russians join Cossacks in attacking the Jews—Charles X of Sweden—The Polish Fugitives—"Polonization" of Judaism. 1648–1656 C. E. Poland ceased to be a haven for the sons of Judah, when its short-sighted kings summoned the Jesuits to supervise the training of the young nobles and the clergy and crush the spirit of the Polish dissidents. These originators of disunion, to whom the frequent partition of Poland must be attributed, sought to undermine the unobtrusive power which the Jews, through their money and prudence, exercised over the nobles, and they combined with their other foes, German workmen and trades-people, members of the guilds, to restrict and oppress them. After that time there were repeated persecutions of Jews in Poland; sometimes the German guild members, sometimes the disciples of the Jesuits, raised a hue and cry against them. -
Tithing in 10 Baby Steps
Tithing in 10 Baby Steps A Users Guide to The Great Tithe Experiment Mike McGuire 1 This is written for you. You wanted to tithe. Now is the time. 2 The Ten Baby Steps Preface 4 1 Ask “Why?” 5 2 Ask “Why Not?” 12 3 Commit 16 4 Calculate 19 5 Count the Cost 21 6 Develop a Plan 24 7 Determine the Method 27 8 Give Now 29 9 Persevere Through Challenges 31 10 Enjoy the Benefits 33 About the Author 36 The Great Tithe Experiment 37 Notes 38 3 Preface Dear Reader, I want to help you to fulfill your desire to give. This short book takes a big step of faith and breaks it into small baby steps. I have found tithing to be one of the most fruitful spiritual disciplines resulting in a closer relationship to God and a further separation from material pursuits. Our church recently conducted an experiment to measure the effects of tithing. In total, 52 individuals participated, which included 13 households, who started tithing for the first time. You’ll receive highlights of their story in this ebook. A richer spiritual life is only 10 baby steps away. I hope you will join us. Mike McGuire 4 1 Ask “Why?” Tithing is a simple concept. It means donating 10% of your income to your local church. It’s simple, but for many Americans, not easy. One couple who took the experiment remarked, “I wrote my first check and said, ‘Oh, my gosh, that is a lot of money!’ ” The first question to ask is, “Why?” Why in the world would one give away their hard-earned income? And, why 10%? Baby Step #1 – Ask “Why?” Why should you give 10% of your income to a local church? Those are fair and appropriate questions. -
Fixing the Constitutional Absurdity of the Apportionment of Direct Tax Calvin H
University of Minnesota Law School Scholarship Repository Constitutional Commentary 2004 Fixing the Constitutional Absurdity of the Apportionment of Direct Tax Calvin H. Johnson Follow this and additional works at: https://scholarship.law.umn.edu/concomm Part of the Law Commons Recommended Citation Johnson, Calvin H., "Fixing the Constitutional Absurdity of the Apportionment of Direct Tax" (2004). Constitutional Commentary. 103. https://scholarship.law.umn.edu/concomm/103 This Article is brought to you for free and open access by the University of Minnesota Law School. It has been accepted for inclusion in Constitutional Commentary collection by an authorized administrator of the Scholarship Repository. For more information, please contact [email protected]. Articles FIXING THE CONSTITUTIONAL ABSURDITY OF THE APPORTIONMENT OF DIRECT TAX Calvin H. Johnson* The Constitution requires that direct taxes be apportioned among the states according to population. 1 Before the abolition * Professor Law, University of Texas. A table of short form citations to fre- quently cited documentary sources is found in the Appendix. 1. The Constitution of the United States provides: Representatives and direct Taxes shall be apportioned among the several States ... according to their respective Numbers, which shall be determined by adding to the whole Number of free Persons, including those bound to Service for a Term of Years, and excluding Indians not taxed, (but including] three fifths of all other Persons. U.S. CONST. art. I, § 2, cl. 3. The three-fifths of "all other Persons" referred to slaves, but the Thirteenth Amendment abolished slavery. See also U.S. CONST. art. 1, § 9, cl. 4 (providing that "[n]o Capitation, or other direct, Tax shall be laid, unless in Proportion to the Census or Enumeration herein before di rected to be taken"). -
More Than 50 Years of Trade Rule Discrimination on Taxation: How Trade with China Is Affected
MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED Trade Lawyers Advisory Group Terence P. Stewart, Esq. Eric P. Salonen, Esq. Patrick J. McDonough, Esq. Stewart and Stewart August 2007 Copyright © 2007 by The Trade Lawyers Advisory Group LLC This project is funded by a grant from the U.S. Small Business Administration (SBA). SBA’s funding should not be construed as an endorsement of any products, opinions or services. All SBA-funded projects are extended to the public on a nondiscriminatory basis. MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY.............................................................................................. iv INTRODUCTION ................................................................................................................ 1 I. U.S. EXPORTERS AND PRODUCERS ARE COMPETITIVELY DISADVANTAGED BY THE DIFFERENTIAL TREATMENT OF DIRECT AND INDIRECT TAXES IN INTERNATIONAL TRADE .............................................. 2 II. HISTORICAL BACKGROUND TO THE DIFFERENTIAL TREATMENT OF INDIRECT AND DIRECT TAXES IN INTERNATIONAL TRADE WITH RESPECT TO BORDER ADJUSTABILITY................................................................. 21 A. Border Adjustability of Taxes ................................................................. 21 B. 18th and 19th Century Examples of the Application of Border Tax Adjustments ......................................................................... -
Mass Taxation and State-Society Relations in East Africa
Chapter 5. Mass taxation and state-society relations in East Africa Odd-Helge Fjeldstad and Ole Therkildsen* Chapter 5 (pp. 114 – 134) in Deborah Braütigam, Odd-Helge Fjeldstad & Mick Moore eds. (2008). Taxation and state building in developing countries. Cambridge: Cambridge University Press. http://www.cambridge.org/no/academic/subjects/politics-international-relations/comparative- politics/taxation-and-state-building-developing-countries-capacity-and-consent?format=HB Introduction In East Africa, as in many other agrarian societies in the recent past, most people experience direct taxation mainly in the form of poll taxes levied by local governments. Poll taxes vary in detail, but characteristically are levied on every adult male at the same rate, with little or no adjustment for differences in individual incomes or circumstances. In East Africa and elsewhere in sub-Saharan Africa, poll taxes have been the dominant source of revenue for local governments, although their financial importance has tended to diminish over time. They have their origins in the colonial era, where at first they were effectively an alternative to forced labour. Poll taxes have been a source of tension and conflict between state authorities and rural people from the colonial period until today, and a catalyst for many rural rebellions. This chapter has two main purposes. The first, pursued through a history of poll taxes in Tanzania and Uganda, is to explain how they have affected state-society relations and why it has taken so long to abolish them. The broad point here is that, insofar as poll taxes have contributed to democratisation, this is not through revenue bargaining, in which the state provides representation for taxpayers in exchange for tax revenues (Levi 1988; Tilly 1990; Moore 1998; and Moore in this volume). -
Tax Policy of Estonia in the Framework of the EU Integration
Tax Policy of Estonia in the framework of the EU Integration Tax Policy of Estonia in the framework of the EU Integration Thesis to obtain the degree of Doctor from the Erasmus University Rotterdam by command of the Rector Magnificus Prof. dr S.W.F. Lambert and according to the decision of the Doctorate Board The public defence shall be held on Thursday 29 September 2005 at 13:30 hrs by Aiki Kuldkepp Doctoral Committee Promotors: Prof. mr. drs. H.P.A.M. van Arendonk and Prof. dr. M.P. van der Hoek Other members: Prof. dr. A.Purju Prof. dr. H.A. Kogels Prof. mr. M.J.W.M. Ellis Table of contents Introduction ..............................................................................................................................1 Some historical facts about Estonian accession to the EU.............................................................1 Objectives of the research ..............................................................................................................2 Outline of the research ...................................................................................................................2 1 Tax policy of Estonia..........................................................................................5 1.1 Overview of Estonian tax policy since 1990........................................................5 1.1.1 Introduction of tax system after regaining independence.....................................5 1.1.2 Introduction of flat rate income tax......................................................................5 -
Reconsidering the Taxation of Foreign Income James R
University of Michigan Law School University of Michigan Law School Scholarship Repository Articles Faculty Scholarship 2009 Reconsidering the Taxation of Foreign Income James R. Hines Jr. University of Michigan Law School, [email protected] Available at: https://repository.law.umich.edu/articles/199 Follow this and additional works at: https://repository.law.umich.edu/articles Part of the Taxation-Transnational Commons, and the Tax Law Commons Recommended Citation Hines, James R., Jr. "Reconsidering the Taxation of Foreign Income." Tax L. Rev. 62, no. 2 (2009): 269-98. This Article is brought to you for free and open access by the Faculty Scholarship at University of Michigan Law School Scholarship Repository. It has been accepted for inclusion in Articles by an authorized administrator of University of Michigan Law School Scholarship Repository. For more information, please contact [email protected]. Reconsidering the Taxation of Foreign Income JAMES R. HINES JR.* I. INTRODUCTION A policy of taxing worldwide income on a residence basis holds enormous intuitive appeal, since if income is to be taxed, it would seem to follow that the income tax should be broadly and uniformly applied regardless of the source of income. Whether or not worldwide income taxation is in fact a desirable policy requires analysis ex- tending well beyond the first pass of intuition, however, since the con- sequences of worldwide taxation reflect international economic considerations that incorporate the actions of foreign governments and taxpayers. Once these actions are properly accounted for, world- wide taxation starts to look considerably less attractive. Viewed through a modern lens, worldwide income taxation by a country such as the United States has the effect of reducing the incomes of Ameri- cans and the economic welfare of the world as a whole, prompting the question of why the United States, or any other country, would ever want to maintain such a tax regime. -
Sustainable Public Finance: Double Neutrality Instead of Double Dividend
Journal of Environmental Protection, 2016, 7, 145-159 Published Online February 2016 in SciRes. http://www.scirp.org/journal/jep http://dx.doi.org/10.4236/jep.2016.72013 Sustainable Public Finance: Double Neutrality Instead of Double Dividend Dirk Loehr Trier University of Applied Sciences, Environmental Campus Birkenfeld, Birkenfeld, Germany Received 27 November 2015; accepted 31 January 2016; published 4 February 2016 Copyright © 2016 by author and Scientific Research Publishing Inc. This work is licensed under the Creative Commons Attribution International License (CC BY). http://creativecommons.org/licenses/by/4.0/ Abstract A common answer to the financial challenges of green transformation and the shortcomings of the current taxation system is the “double dividend approach”. Environmental taxes should either feed the public purse in order to remove other distorting taxes, or directly contribute to financing green transformation. Germany adopted the former approach. However, this article argues, by using the example of Germany, that “good taxes” in terms of public finance should be neutral in terms of environmental protection and vice versa. Neutral taxation in terms of environmental im- pacts can be best achieved by applying the “Henry George principle”. Additionally, neutral taxation in terms of public finance is best achieved if the revenues from environmental taxes are redistri- buted to the citizens as an ecological basic income. Thus, distortive effects of environmental charges in terms of distribution and political decision-making might be removed. However, such a financial framework could be introduced step by step, starting with a tax shift. Keywords Double Dividend, Double Neutrality, Tinbergen Rule, Henry George Principle, Ecological Basic Income 1. -
To Tithe Or Not to Tithe?
To tithe or not to tithe? Considering proportional giving: A guide for everyone © The United Reformed Church 2016 Scripture taken from the Holy Bible, NEW INTERNATIONAL VERSION®, NIV® Copyright © 1973, 1978, 1984, 2011 by Biblica, Inc.® Used by permission. All rights reserved worldwide. How much should we give? Christians often ask: how much money should I give to the work of the church? And this is often answered by the church treasurer who, on presenting a budget which shows the expenditure as being greater than the income, then appeals to congregation to increase their giving so as to balance the budget. But perhaps a different approach should be taken. God is not calling on us to simply meet a specific need; he is calling on us to give of our resources willingly and cheerfully as a response to his generosity to, and love for, us. What does the Bible say? The Bible has a great deal to say about money! The Old Testament introduces the idea of tithing. This is giving the first tenth of your income to God and living on the rest. Some biblical scholars have calculated that, if people gave according to the original Old Testament laws on tithing, including the special tithes, then each person would be giving 23% of their annual income to God in tithes. Tithing and the Old Testament In the Old Testament there are a number of passages that specifically call on God’s people to give a tithe. Here are some of them which we invite you to read, consider and perhaps discuss in small groups. -
WT/CTE/W/47 2 May 1997 ORGANIZATION (97-1913)
RESTRICTED WORLD TRADE WT/CTE/W/47 2 May 1997 ORGANIZATION (97-1913) Committee on Trade and Environment TAXES AND CHARGES FOR ENVIRONMENTAL PURPOSES - BORDER TAX ADJUSTMENT Note by the Secretariat I. INTRODUCTION The following Note has been prepared by the Secretariat on request by the Committee on Trade and Environment. It is organized in three parts: (a) a brief presentation of various policy instruments to address environmental problems; (b) a discussion of the wider economic and trade implications of eco-taxes and -charges; and (c) an overview of WTO provisions and dispute settlement practice pertaining to the application of domestic taxes and charges to traded goods. II. CURRENT USE OF ENVIRONMENT-RELATED TAXES AND CHARGES A. General features 1. Environmental policies in many countries continue to shift from relying predominantly on remedial actions to controlling pollution and other environmental effects. There is an increasing focus on correcting the causes underlying environmental problems and preventing over-intensive resource use, rather than on curing symptoms. The causes are often associated with the failure of market prices to correctly reflect environmental scarcities and/or social values.1 2. While governments may use a wide array of measures to pursue public policy objectives, including environmental goals, two principle approaches can be distinguished: command-and control measures such as prohibitions or quantitative controls on the one hand, and price-based instruments such as tariffs, taxes or subsidies on the other. In practice, both approaches may be combined. Quantitative limits may be employed, for example, to circumscribe maximum permissible levels of an activity, e.g. -
Assessment Solutions: Direct and Indirect Taxes
Assessment Solutions Theme 4: What Is Taxed and Why Lesson 4: Direct and Indirect Taxes Part 1 Match the descriptions to their correct key terms. Write the letters of the correct key terms on the lines provided. Answer Key: A. sales tax B. business C. individual D. direct E. indirect C 1. Personal income tax is paid by this type of income earner D 2. A tax which cannot be shifted B 3. To recover an increase in its taxes, this type of taxpayer may increase its prices to its customers E 4. A tax which can be passed on to another A 5. Stores often pass along the cost of this type of state and local tax Part 2 Indicate whether each of the statements below is True or False. Write true if the statement is true. Write false if the statement is false. Write your answers in the space provided. 1. A direct tax cannot be shifted to another. True 2. Individual income tax is an example of a direct tax. True 3. To recover business taxes, an owner cannot pass along the charges. False Understanding Taxes 1 4. Consumers often pay some or all business taxes when they purchase goods and services. True 5. Ultimately, only a business owner pays the cost of business property tax. False Part 3 Classify each tax below as either Direct or Indirect. Write the letter of the correct choice in the space provided. B 1. Sales tax A. direct tax B. indirect tax A 2. Personal income tax A. direct tax B.