International Tax Issues Relating to Globalization: Congressional Hearing

Front Cover
William V. Roth, Jr.
DIANE Publishing, 1999 - 166 pages
 

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Contents

I
1
II
2
III
3
IV
5
V
8
VI
9
VII
11
VIII
17
XX
58
XXI
79
XXII
81
XXIII
88
XXIV
91
XXV
96
XXVI
101
XXVII
102

IX
19
X
22
XI
25
XII
28
XIII
30
XIV
32
XV
41
XVI
43
XVII
52
XIX
55
XXVIII
109
XXIX
111
XXX
119
XXXI
138
XXXII
140
XXXIII
141
XXXIV
142
XXXV
144
XXXVI
145
XXXVII
164

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Page 150 - return information" means— (A) a taxpayer's identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies...
Page 140 - ... and subpart F provisions to make them the exclusive anti-deferral provisions of the Code. For the reasons set forth in this statement, if the foreign personal holding company provisions ultimately are retained, they should be modified this year to apply the PFIC look-through rules (section 1296(c)) in determining whether a foreign corporation is a foreign personal holding company. Explanation of Proposal The foreign personal holding company rules were enacted in 1937 to eliminate the opportunity...
Page 79 - F was first enacted in 1962, the basic intent was to require current US taxation of foreign income of US multinational corporations that was passive in nature. The 1962 law was careful not to subject active financial services business income to current taxation, through a series of detailed carve-outs.
Page 150 - Investigation or processing, or any other data, received by, recorded by, prepared by. furnished to, or collected by the Secretary with respect to a return or with respect to the determination of the existence, or possible existence, of liability (or the amount thereof) of any person under thl
Page 114 - Other countries may rely to a greater degree on government assessment and negotiation between taxpayer and government — traits which may lead to more government intervention in the affairs of its citizens, less even and fair application of the law among all affected citizens and companies, and less certainty and predictability of results in a given transaction. In some other cases, the complexity of the US system may simply be ahead of development along similar lines in other countries — many...
Page 150 - return information" in part, as follows: (A) a taxpayer's identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies, overassessments, or tax payments, whether the taxpayer's return was, is being, or will be examined or subject to other investigation or processing, or any other data, received by, recorded by.
Page 165 - American Chambers of Commerce Abroad, an increasing number of members are engaged in the export and import of both goods and services and have ongoing investment activities. The Chamber favors strengthened international competitiveness and opposes artificial US and foreign barriers to international business. Positions on national issues are developed by a cross section of its members serving on committees, subcommittees and task forces.
Page 80 - American finance and credit companies, banks, securities firms, and insurance companies will be impaired by an "on-again, off-again" system of annual extensions that does not allow for certainty.
Page 102 - The Investment Company Institute is the national association of the American investment company industry. Its membership includes 4,582 open-end investment companies ('mutual funds'), 433 closed-end investment companies and 13 sponsors of unit investment trusts.
Page 106 - US multinationals did not establish affiliates abroad to produce for the local market, they would be too distant to have an effective presence in that market. In addition, companies from other countries would either establish such facilities or increase exports to that market. In effect, it is not really possible to sustain exports to such markets in the long run. On a net basis, it is highly doubtful that US direct investment abroad reduces US exports or displaces US jobs.

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