This volume brings together a number of new studies concerned with some of the topical problems of taxation. In Part I, limits of taxation are considered from the viewpoint of normative tax theory, its relation to the 'hidden' economy, and in terms of empirical estimates of the effects of taxes. Part II contains three theoretical studies which extend the theory of income taxation and redistribution. Part III deals with the corporate tax and contains both theoretical and empirical contributions. In conclusion, Part IV is devoted to two analyses of alternatives to income and corporate taxation. The authors represent a number of different countries and viewpoints.

Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples. This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable.