Premium Essay

Tax Examinations Abroad Analysis

Submitted By
Words 742
Pages 3
Review and implementation of measures that improve Tax Examinations Abroad
As part of the continuous improvement cycle, tax administration compliance officials should, based on the recommendations contained in final reports and after consultation with the tax examinations coordinator and other compliance personnel, seek to implement changes to tax examinations compliance procedures and programs. Any material changes to the tax administration’s tax examinations procedures should be brought to the notice of the competent authorities of their tax treaty partners as soon as possible. It follows that any training materials/courses on tax examinations abroad procedures are updated to reflect these changes.
4.14 Minimum Attributes of an Exchange …show more content…
A legal basis to exchange must exist. That basis should have:
I. A treaty or Tax Information Exchange Agreement network (even it is just one);
II. Domestic laws that allow the tax administration to gather information on behalf of another tax administration and then exchange the information with another tax …show more content…
The ability to follow up written procedures; tracking and filing systems for cases, program history, and policy; the ability of its personnel to meet with counter parts to resolve differences; a policy making structure (maybe internal, external or both) and written policies; the ability to direct field personnel to gather information; the ability to modify procedures and policies as necessary; the ability to protect the information gathered and exchanged under the treaty; a legal staff to advise it on issues and defend it in court if necessary. Intangibles like a tax administration has to be able to provide information when a request is received, dedicated staff who understands all the issues involving Exchange of Information and who can serve as points of contacts for treaty partners and other internal tax administration

Similar Documents

Premium Essay

Macro Management

... | |Official Time Table of the course | |Approved course syllabus signed by Instructor & Program chair | |Objective and Outcome Mapping | |Lesson Plan | |Assessment Scheme and Schedule | |Model Question Paper (Semester End Examination (SEE)) | |Lectures Slides, Tutorials and other Learning Resource provided (See Annexure 1) | |Assignments / Course Projects | |Evaluated samples of Assignments / Course Projects (One sample each from Excellent, Average and Satisfactory Bands) (See | |Annexure 2: Hard Copy of Evaluated Project Reports) | |Quizzes and CAT-I & II question papers and...

Words: 7055 - Pages: 29

Premium Essay

Stratergic Managment

...Session 14 - International Taxation � Provide an overview of the taxation of international tax rules � Introduce the FTC � Provide an overview of transfer pricing 15.518 Fall 2002 Session 14 International tax systems � Territorial - no tax is generally due on income earned outside of the country in which the parent is located � Worldwide - all income is subject to taxation by the country in which the parent is located # US taxes worldwide income of citizens and permanent residents US taxes worldwide income of domestic corporations US taxes the US source income of nonresident aliens US taxes the US source income of foreign corporations # # # 15.518 Fall 2002 Session 14 Withholding � In addition to taxes imposed on earnings, transfers (interest payments, dividends, royalties, etc.) between a corporation and its foreign shareholders (individuals or corporations) are generally subject to withholding taxes. � The general withholding rate imposed by the U.S. is 30% of the payment amount. This rate can be reduced by tax treaties between the various jurisdictions 15.518 Fall 2002 Session 14 Some definitions � A domestic corporation is one incorporated in one of the 50 US states � A foreign corporation is one that is not a domestic corporation � We will focus on taxation of corporations rather than individuals or partnerships 15.518 Fall 2002 Session 14 U.S. Framework � Worldwide taxation � Elimination of double taxation � Deferral � “Arm's-Length” related party...

Words: 2955 - Pages: 12

Free Essay

Imba

...B. Finance Specialization Requirements (12 semester hours): Term Two (spring) | | | IMB 531 Portfolio Analysis and Management I: Equity | (2) | | IMB 532 Portfolio Analysis and Management II: Fixed Income | (2) | | IMB 533 Portfolio Analysis and Management III: Derivatives and Financial Risk Management | (2) | | IMB 536 Global Macroeconomic Trends and Financial Institutions or CSB Elective | (1) | | IMB 534 International Real Estate Investment | (1) |   | IMB 539 Financial Management | (2) | | IMB --- CSB Elective | (2) | | Or | | | | | | IMB 595 Special Topics in International Business (to be completed at an IBSA partner school) | | C. Thesis or Extensive Written Case Analysis (12 semester hours): Term 3 (summer) |   |   | IMB 599 Thesis | (6) | | IMB 594 Capstone Project / Practicum | (6) | IMBA Course Descriptions (UNCW) The course descriptions shown below are only for courses offered by UNCW and the Cameron School of Business. See each alliance school for their course offerings. IMB 531. Cases in International Finance (1-2) This course will focus on international financial management cases. Cases will build on topics of international monetary systems, international investment decisions, portfolio diversifications, multinational capital structure, and foreign exchange risk and management. IMB 532. Portfolio Analysis and Management I (2) This course is designed to focus on tool and techniques of modern portfolio theory in...

Words: 797 - Pages: 4

Premium Essay

Csusb Mba Catalog 2012-2014

...Requirements (48 units) The Master of Business Administration (M.B.A.) program provides postbaccalaureate students with a high-quality master-level education in the field of business administration. The program is designed to prepare promising students for positions of increasing responsibility and leadership through education in the broad scope of business and through in-depth knowledge in one or more specialized areas of business. The program is open to all qualified students, regardless of undergraduate major. Students who do not have a background in the area of business administration can obtain this required capability by completing designated prerequisite courses or through individual study with competency demonstrated through credit by examination or by demonstrated work experience. Admission to the M.B.A. Program In addition to the general requirements of the university, specific requirements for admission to classified graduate status are: 1. A bachelor's degree from an accredited college or university; 2. Submission of an acceptable Graduate Management Aptitude Test (GMAT) test score that meets the following conditions: a. Minimum GMAT score of 470, minimum 10% on GMAT Verbal Ability and Quantitative Ability percentile rankings; b. Minimum grade point average of 2.5, GPA is...

Words: 5568 - Pages: 23

Premium Essay

Mercantile Credit Bank

...CAMBRIDGE INTERNATIONAL EXAMINATIONS GCE Advanced Level e ap .c rs om MARK SCHEME for the May/June 2011 question paper for the guidance of teachers 9707 BUSINESS STUDIES 9707/31 Paper 3 (Case Study), maximum raw mark 100 This mark scheme is published as an aid to teachers and candidates, to indicate the requirements of the examination. It shows the basis on which Examiners were instructed to award marks. It does not indicate the details of the discussions that took place at an Examiners’ meeting before marking began, which would have considered the acceptability of alternative answers. Mark schemes must be read in conjunction with the question papers and the report on the examination. • Cambridge will not enter into discussions or correspondence in connection with these mark schemes. Cambridge is publishing the mark schemes for the May/June 2011 question papers for most IGCSE, GCE Advanced Level and Advanced Subsidiary Level syllabuses and some Ordinary Level syllabuses. Page 2 1 Mark Scheme: Teachers’ version GCE A LEVEL – May/June 2011 Syllabus 9707 Paper 31 Analyse the advantages and disadvantages for AC of greater use of electronic methods of communication. [10] Knowledge 3 marks Level 2 3 marks Two or more relevant points made or one point made plus knowledge of communication shown. 1–2 marks One relevant point made or knowledge of communication shown. Application 2 marks 2 marks Points made are well applied to case. Analysis 5 marks 3–5 marks...

Words: 2494 - Pages: 10

Premium Essay

Hdfc Bank Case Study

...This bank also considered as a authorized host branch for the collection of direct tax. Brief Profiles of Selected Private Sector Banks in India 1.9.1 History and Profile of Industrial Credit and Investment Corporation of India (ICICI):- ICICI Bank is the largest private sector bank in India which was established in 1994, In September 10, 1999, The bank has a network of 4,450 branches and 13,995 ATMs in India, and has a presence in 19 countries including India. It offers a range of banking products and services for corporates and retail customers of a bank through an inconsistency of delivery channels and its specific subsidiaries in the areas of investment banking, life and non- life insurance, effective asset management and venture capital...

Words: 989 - Pages: 4

Premium Essay

Taxes and Va

...University of Wisconsin, Madison, Wisconsin Brett Jones is a senior accountant with the accounting firm of BGW. On a recent audit engagement, Brett was assigned the task of evaluating the deferred tax accounting for Packer Inc. The company, founded in 1962, is a large heavy machinery manufacturer. Packer’s balance sheet at December 31, 1997 includes a deferred tax asset of approximately $22 million related to net future deductible temporary differences. However, realization of the deferred tax asset is dependent upon profitable operations in the U.S. and abroad, and future reversals of existing temporary differences. Although realization is not assured, Packer management in the past has been pretty sure that such benefits will be realized through the reduction of future taxable income. Management has carefully considered various factors in assessing the probability of realizing these deferred tax benefits. Brett recalls the complexity surrounding the judgmental nature of accounting for deferred taxes under generally accepted accounting principles. Under Statement of Financial Accounting Standard No. 109 (FAS 109), Packer could be required to record a deferred tax asset for future deductible amounts and carry-forwards and record a valuation allowance, if it is likely that the tax asset will not be realized. Brett also recalls that FAS 109 provides some examples of negative evidence to support recording a valuation allowance, and positive evidence to avoid recording a valuation...

Words: 1458 - Pages: 6

Premium Essay

Gastronomy

...of tourism in a selected micro-region or region through comparative research. 6. The role of training, marketing and advertising in operating rural tourism by indicating a specific area. 7. The impact of tourism developments in Hungary on the life of a settlement or micro-region. Analysis of the impact of developments from economic, ecological and social aspects. 8. Foreign interests in the domestic tourism market. Motivations, targeted areas, concentration of capital and globalisation ambitions. 9. Development of Hungary’s competitiveness in the field of active international tourism, giving a comparative analysis. 10. Actualities of aquatic sports tourism (cyclist tourism, etc.) in Hungary. Motivations, specific expenditure, possibilities, infrastructure, shortcomings and the analysis of the situation at home and abroad. We will accept only one entry per topic. 11. The competitiveness of the Hungarian MICE tourism offer. International survey. Development trends and the expected impact on budget revenue from tourism. 12. Comparative assessment of tenders for central and regional tourism developments. Preliminary impact analysis. Application of economical aspects in the field of regional/local...

Words: 1483 - Pages: 6

Premium Essay

Measurement of Crm Technologies

...COVER PAGE WITH LOGO CONTENTS Introduction....................................................................................................... 3 Company Profile............................................................................................... 4 Measurement of CRM Technologies................................................................ 9 * Informationg Gathering Process................................................... 9 * Storing the information and Analyzing the Data.......................... 12 * Delivering Information................................................................. 17 * Integrated Front Ofiice................................................................. 19 * The next development.................................................................. 20 Practices of Relationship Marketing................................................................. 21 * Relationship marketing from boc’s point of view....................... 21 * Activities undertaken to develop relationships with customers... 23 * Different Levels of relationship Marketing.................................. 29 INTRODUCTION The Bank of Ceylon is the premier state owned commercial bank in Sri Lanka which has been operating in the banking industry for the past 72 years since 1939. Bank of Ceylon has evolved continuously over the years, undergoing changes in its business operations, branch network, ownership...

Words: 6022 - Pages: 25

Premium Essay

Transfer Price

...cross international boundaries, involve tax issues concerning the determination, analysis and adjustment of prices between this related entities. I. Transfer price 1. Transfer price definition The transfer prices are the prices at which an enterprise transfers physical goods and intangible property or provides services to associate enterprises. They are the prices charged for any transaction between affiliates entities. This transfer may be commercial, financial or technical. According to the OECD, two companies are associated if one of the enterprises participates directly or indirectly in the governance, management, control or the capital of the other or if the same persons participate directly or indirectly to the management, control or the capital of both enterprises. They can be defined simply as transactions prices between companies of the same group and resident in different states. This type of transactions involves intra-group transactions crossing borders. Example: Within a MNE group, a subsidiary A established in France sells computers to another subsidiary B established in Britain, the selling price of computers is a price transfer. The goal of the transfer pricing rules is to accurately measure income between related parties by determining the “arm’s length” price that the selling company would charge an unrelated party. 2. Arm’s length principle According to the Article 9 of the OECD Model Tax Convention, the arm’s length principle...

Words: 2245 - Pages: 9

Free Essay

Bail

...* there must be some proof and not mere opinion in the shape of a statement. * ---Names of accused were not mentioned in F.I.R. nor description of their features or their stature was given---Accused had not been identified and their identification test took place two- months after incident---Alleged identification of accused was based on flashing of torch light which was a weak form of identification. * When material on record was not showing as to which accused caused fatal injury leaving room for consideration regarding common intention of other accused, such case called for further enquiry- * ---Assessment of evidence ---Principle---Deeper appreciation of record cannot be gone into at bail stage, but only its tentative Assessment is to be made just to find out as to whether the accused is, prima facie, connected with the commission of crime or not. * ---No final findings could be given regarding plea of alibi at bail stage, as same would require recording of evidence ---Tentative Assessment of such plea, could be made, if it was found that accused had succeeded in establishing an opposite version then the case of accused would become one of further inquiry and on that score, accused would become entitled to the concession of bail. * one of accused was shown as armed with dagger, while other with Kalashinikov---Injuries sustained by the complainant were blunt which could be the result of danda attributed to absconding accused---No role seemed of accused persons...

Words: 11061 - Pages: 45

Premium Essay

Actg 3120 Course Outline

...Course Outline ACTG 3120.3.0 : Intermediate Financial Accounting II Section: T Class: Tuesdays, 11:30am – 2:30pm Lab: Wednesdays, 5:30pm - 7:00pm Instructor Liz Farrell (416)736-5063 or (416)736-2100, ext. 66522 S345 Seymour Schulich Building efarrell@schulich.yorku.ca Office hours: Mondays, 8:00 - 8:30 am Tuesdays, 10:30 - 11:30 am Wednesdays, 8:00 - 8:30 am Secretary Filomena Petrilli 416-736-5063 S344K Seymour Schulich Building fpetrill@schulich.yorku.ca Brief Description This is an extension of SB/ACTG 3110.03, but with a primary focus on the valuation and presentation of liabilities and owners' equity. Major topics include current, long-term and contingent liabilities; leases; pensions; corporate income tax allocation; capital transactions, earnings per share and analysis of financial statements under differing accounting policies. The criteria by which both preparers and users make decisions are emphasized. Prerequisite[s] / Co-requisite[s] Note: Not available to exchange students visiting Schulich. Prerequisite: SB/ACTG 3110 3.00 Course objectives and detailed description The objective of this course is to provide students with an indepth understanding of the accounting for the liabilities and equities side of the balance sheet. This includes both international accounting standards (Part I of CICA Handbook) and the accounting standards for private enterprises (Part II of CICA Handbook). This course is the continuation of a two-course sequence (ACTG 3110/3120) that deals...

Words: 5303 - Pages: 22

Premium Essay

Cpa V Cma

...CPA’S and CMA’s. Below are some of the differences discussed in paragraphs. CPA, which stands for Certified Public Accountant, is the more popular certification between the two. “It is also the most widely accepted and accredited certification for an accountant”( Harden, G ,2008 ) . Moreover, according to bureau of labor statistic, CPAs mostly handles tasks such as auditing, taxes, and preparing financial statements to ensure that an individual or company is able to meet the legal financial requirements mandated by local government agencies. CMA, on the other hand, stands for Certified Management Accountant. Accountants that receive this certification are more concern with handling responsibilities pertaining financial management, budget analysis and strategies. On top of that, Certified Management Accountants are also expected to have the ability to lead employees, and have enough business know-how to allow the company or organization to succeed. Moreover, another difference between the CPA and CMA certifications, are the requirements needed to qualify for the exams. Both the CPA and CMA...

Words: 1398 - Pages: 6

Premium Essay

Asdfhhg

...What Is Globalization? Globalization can be explained as a process of integration and interaction among the companies, people, and governments of different nations. It is a process explained by international trade and investment and updates by information technology. There is an amazing irony in globalization and it is that, as the world gets smaller, opportunities for growth and development become wider and better. Nowhere is this more clearly manifest than in the sphere of international trade and business relations where foreign market economies, domestic politics and diverse legal systems are linked to each other to create more advantages for the contracting states. Origin of Globalization The origin of the Globalization is not new one. It has been gone thousands of years, first people, and, then later on the corporations and industries have been selling to and buying from each other in different lands and nation’s at large distances. This origin of globalization can be elaborated by taking an example of Silk Road. The Silk Road is an entity that is connecting the Europe and China during the middle ages. The same, for centuries, industries and people have been investing in enterprises and venture in other countries. If truth be told, there are number of characteristics of the contemporary wave of globalization are parallel to those existing before the occurrence of the First World War in 1914. Brecher et al. try to conceptualize the roots of...

Words: 1978 - Pages: 8

Premium Essay

Bbs Introduce of Bbe

...ASB-3101 HUMAN RESOURCE MANAGEMENT Credits: 10 Contact hours: 23 Semester: 1 Pre-requisites: ASB-2104 Module organiser: Sally Sambrook Note: This module is available through the medium of Welsh (ACB-3101). Aims: To examine issues and developments in the field of contemporary human resource management (HRM). To develop an understanding of the complex issues facing human resource (HR) specialists and line managers in meeting their responsibilities for selecting, deploying, training, appraising, rewarding, relating to and retaining human resources. Learning Outcomes: On completing the module, students are expected to be able to: • Explain the contribution of the HR function to corporate strategy; • Discuss the processes of recruitment, assessment and selection; • Outline activities involved in developing human resources and facilitating learning; • Explain the link between rewards, motivation and performance; • Critically evaluate the changing employment relationship, assessing the role of trade unions and other forms of employee involvement. Module Content: • History of the HR function, theories and models of HRM; • The roles and responsibilities of stakeholders in HRM; • The changing nature of work, managing diversity, technology and flexibility; • Human resourcing: recruitment and selection, human resource planning; • Reward and performance management; • Employee relations, employment legislation...

Words: 9120 - Pages: 37