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13 Cards in this Set

  • Front
  • Back
What is estoppel?
Judicial estoppel or res judicata where the orders or judgments made in previous legal proceedings prevent the parties from relitigating the same issues or causes of action
In international taxation, What are the two bases for taxation?
1) Residence
2) Source
How is residence determined for companies?
A company is considered to be a resident of a State if it is liable to tax, in that State, by reason of factors (domicile residence, incorporation or place of management) that trigger the widest domestic tax liability.
Which tax basis typically takes precedence?
What are the two types of income taxes?
1)On gross income
2)On net income
How do US tax exclusions work?
The US provides a tax credit that is equal to the amount of the foreign tax up to the amount of a hypothetical US tax for that foreign source income
What is a withholding tax?
A tax on certain types of income due to difficulties of enforcement (e.g., interest, dividend, royalties and other passive forms of income).
In what 2 cases are there no withholding taxes?
1)Income from capital gains
2)Real business income (from the sale of services or goods)
What is permanent establishment?
The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
What are two general exceptions to permanent establishment?
•Websites, hosting arrangements, ISPs, and servers rarely, if ever, constitute a PE.
•Some categories of profits may be taxed in a country even though there is no PE (immovable property, performance of entertainers and athletes, provision of services longer than 6 months)
When thinking about taxation, what does the term neutrality refer to?
Taxes levied on non-residents are equivalent to those levied on residents.
What are the six important features of international tax treaties?
4)effectiveness and fairness
5)simplicity and certainty
6)compatibility with international trade rules
Why is it important to have universally-agreed rules?
In order to avoid double taxation or non-taxation of business profits