...Services income • The place of performance of the services • FCT v Efstathakis – Greek national worked for the Greek Press in Aust. → Source of income was Aust - performed relevant work • FCT v French – Australian engineer employed by Aust to work in NZ. → Service was performed in NZ, source of income was NZ • Other factors, such as place of contracting or place of payment may determine source • FCT v Mitchum – American actor entered agreement with Swiss co. Worked on film in Aust. Salary was paid in US. → NO Australian Source - No law stating that source of salary is where work is performed • Evans v FCT – Academic employed by University of Adelaide worked in Switzerland. Received study leave grant was paid in Australian bank account. → Australian source, basis of place of payment Business income • Permanent establishment • Place where business carried on • FCT v United Aircraft Corp – Taxpayer was US resident company, provided info (know how) to reps of an Australia co. who use info to manufacture aircrafts in Aust. Australia paid US. Deemed as royalty payments → No source in Australia – info was supplied in US, payments were not attributable to operations of US or to Australian property Interest income • The source of interest income is the place where the credit is provided: o The place of contracting OR o The place where the funds are advanced • Commer of IR v Philips Gloeilampenfabrieken • Business loans – Where business carried on Dividends •...
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...University of Amsterdam (UvA) http://hdl.handle.net/11245/2.57876 File ID uvapub:57876 Filename WP11.pdf Version unknown SOURCE (OR PART OF THE FOLLOWING SOURCE): Type report Title Tax evasion and the source of income : an experimental study in Albania and the Netherlands Author(s) K. Gërxhani, A. Schram Faculty UvA: Universiteitsbibliotheek Year 2003 FULL BIBLIOGRAPHIC DETAILS: http://hdl.handle.net/11245/1.427430 Copyright It is not permitted to download or to forward/distribute the text or part of it without the consent of the author(s) and/or copyright holder(s), other than for strictly personal, individual use, unless the work is under an open content licence (like Creative Commons). UvA-DARE is a service provided by the library of the University of Amsterdam (http://dare.uva.nl) (pagedate: 2014-11-27)TAX EVASION AND THE SOURCE OF INCOME: AN EXPERIMENTAL STUDY IN ALBANIA AND THE NETHERLANDS AIAS Working Paper 03/11 May 2003 Dr. Klarita Gërxhani AMSTERDAM INSTITUTE FOR Prof. Dr. Arthur Schram ADVANCED LABOUR STUDIES Universiteit van Amsterdam © Klarita Gërxhani Amsterdam, May 2003 This paper can be downloaded at www.uva-aias.net/files/aias/WP11.pdf Amsterdam Institute for Advanced Labour Studies Tax Evasion and the Source of Income: An Experimental Study in Albania and the Netherlands 5 Tax Evasion and the Source of Income: An Experimental Study in Albania and the Netherlands∗ Abstract A series of experiments among different social groups...
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...Pictet-Absolute Return Fixed Income: unlocking the potential of a rapidly-changing bond market Pictet Asset Management May 2014 For professional investors only Overview From 16 to 9. Over the past decade, the number of sovereign borrowers rated triple-A by Standard and Poor's has almost halved. There is probably no clearer testament to the damage caused by the financial crisis. But it is not the only momentous change facing fixed income investors. In another break with the past, policymakers in the developed world no longer worry about the moral hazard of intervening in the capital markets. Driving down real interest rates close to zero has been the policy of choice in the US, UK and Japan, while in the euro zone it has become de rigueur to encourage banks to buy the bonds of those governments with the weakest credit credentials. If dealing with unorthodox monetary and fiscal policies is not challenging enough for fixed income investors, traditional bond benchmarks – and the strategies tied to them – do not help matters. In fact, they often amplify risks. Because these indices are capitalisation- or, perhaps more accurately, liability-weighted, they expose investors to the governments and corporations that issue the most debt. This not only leaves participants vulnerable to the potentially unfavourable shifts in borrower creditworthiness, it also restricts their access to more attractive investment opportunities elsewhere. The bond investor’s plight is further complicated...
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...on international trade.' How far do you agree with this opinion? Use Sources 7, 8 and 9 and your own knowledge. The USA was hit by the Great Depression in 1929 because of increasing restrictions on international trade to a small extent, as it was indeed a significant factor in creating the onset of the Great Depression, as it acted as one of the long-term problems with the US economic system. Source 7 supports this argument, and suggests that it made world trade more difficult as it led to the USA not being able to 'expand its foreign markets as rapidly as its production'. However, other factors could also be considered to have started the Great Depression more significantly, with source 8 suggesting that it was due to long-term problems in the economy associated with a lack of purchasing power and the effects of the Wall Street Crash, along with source 9 demonstrating that it was due to the laissez-faire policies pursued by the Coolidge administration. The USA was arguably hit by the Great Depression in 1929 because of the combination of under consumption and overproduction linked to the maldistribution of wealth in US society during the 1920s. The problem with under consumption was mainly due to the fact that a substantial segment of the population that was farmers and workers in declining industries had not shared in the general prosperity of the early 1920s. In 1929, American farmers annual income averaged at $273, whilst the national average was $750, demonstrating...
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... 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 transactions � Business purpose 15.518 Fall 2002 Session 14 Worldwide Taxation � The U.S. taxes the worldwide income of U.S. corporations (also U.S. individuals, partnerships, estates or trusts)...
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...Under present law, a foreign person or foreign corporation is taxed at a flat rate of 30% on his gross income on his US –source income that is not “connected” with US trade or business. The questions are: • Whether the foreign person is engaged in a US business • If a tax treaty is in effect between the US and the country of the foreign person. If there is an existing tax treaty, the income will not be subject to US tax unless the income is from “permanent establishment” in the US. Trade or Business – Taxpayer engaged in the marketing of goods or services on a regular, continuous and considerable business activity in the US. 1. Performance of personal services- de minimis- foreign persons who is present in the US not more than 90 days during the tax year and receives no more than $3000. 2. Trading in stocks, securities or commodities- through a US broker will not be taxed by US . Congress created several “safe harbor” for trading on the US market and avoid taxes in order to attract foreign investors. A broker, dealers will be taxed because they are regularly engaged in the purchase and sale of stocks for profit or if he maintain an office or other fixed place of business in the US. 3. Other Situation- A. Effect of agency arrangements- b. Partnership, trusts and estates c. Banking- Not all lenders are commercial banks. It will be determined if a foreign person conducting a business by one or more of the activities of: Receiving deposits, making personal loan to the...
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...personalised solutions to achieve your goals and objectives. Mr. Susilo Hatono Your Team of Trusted Specialists Steffi Tedjo Relationship Manager Teo Shih Jie Economist Benjamin Chong Portfolio Manager Lim Chang Tat Equity Product Specialist Cheryl Ong Fixed Income Product Specialist Natasha Wan Alternative Product Specialist 2 1 11/4/2011 Agenda for today’s meeting INTRODUCTION INTRODUCTION + + MACROMACROECONOMIC ECONOMIC OUTLOOK OUTLOOK REVIEW OF MACROREVIEW OF INVESTMENT ECONOMIC INVESTMENT OBJECTIVES OUTLOOK OBJECTIVES - Updated investment - Updated objectives investment objectives current - Review of investments - Review of current investments - Overview of Portfolio PROPOSED PROPOSED ASSET ASSET ALLOCATION ALLOCATION Equities Equities Fixed Income Fixed Income Alternative Alternative Investments Investments - Recap of Portfolio POTENTIAL POTENTIAL CONSIDERACONSIDERATIONS TIONS + + CONCLUSION CONCLUSION 3 Macroeconomic Outlook The Current Investment Environment 4 2 11/4/2011 Global Financial Markets Will there be another global economic downturn? Emerging Markets US Economy Eurozone Debt 5 Euro-zone Crisis – An Introduction Sources of Debt Tax Evasion Debt from Olympics 2004 Pension Rights...
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...International Investment in Insurance Services in the US By Christopher Chan (z3329864), Chun Kin Kwok (z3308661), Jay Jung (z3331738) Abstract This paper proposes several determinants of FDI in insurances services in the US and then examines its relationship and significance to FDI inflows in insurance services by an Ordinary Least Squares (OLS) regression. The regression found that a higher US wage rate discourages FDI in insurance services. However, it also shows that FDI in manufacturing and insurance services complement each other. Thus, the foreign acquisition of US manufacturing assets may have contributed to the almost fourfold increase of FDI inflows in insurance services between 1987 and 1998. 1) Introduction Since the 1980s, many foreign firms have seen the US as a relatively attractive destination for direct investment. Foreign direct investment (FDI)1 allows investors to exert a significant influence on the host country. It creates a global marketplace in which firms from one country are operating another firm in a totally different environment. The US has undergone a major process of restructuring and deregulation that has encouraged this type of investment. In 1998, US FDI inflows accounted for 30% of worldwide FDI inflows (US $193 billion) with the second largest host country (the UK) a distant US$130 billion behind. The dot com bubble in the 90s spurred the nearly doubling of FDI levels in the US in 1998 as overseas firms were eager to tap into the expanding...
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...Publishing, Richard Ivey School of Business Foundation, The University of Western Ontario, London, Ontario, Canada, N6A 3K7; phone (519) 661-3208; fax (519) 661-3882; e-mail cases@ivey.uwo.ca. Copyright © 2011, Richard Ivey School of Business Foundation Version: 2011-07-08 Anna Johnson gazed at the information she had accumulated on various countries and wondered how she could use it to estimate the demand for Kodak Express (KE) outlets. She had learned from the Kodak market research department that demand for KE outlets depended on household income. To support one Kodak Express outlet, one of the following was needed: one million households with annual incomes equal to or exceeding the equivalent of US$15,000, two million households earning the equivalent of between US$10,000 and US$14,999, four million households earning the equivalent of between US$5,000 and US$9,999 or 10 million households with incomes less than the equivalent of US$5,000 (see Exhibit 1). According to the market research department, these averages seemed to apply throughout the world, when international dollars (purchasing power parity adjusted) were used as a benchmark. Unfortunately, the statistics...
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...together in innovative ways. Opportunity Cost-The best alternative, foregoing something, choosing between 2 options, the thing I give up is the opportunity cost (Guns & Butter is about opportunity cost). The graph for the opportunity cost show this: the curve line of the graph is the production possibility curve, the points on the curve tells you that every resources is being used efficiently (factors of production). Point C (outside the curve line) economic growth, w/more resources to use, we get there w/technology. Point A (inside the curve line)is ressession, unemployment, undesirable. Adam Smith, market mechanism(is what it’s called today) invisible hand (goes w/market mechanism) what gets produce, it moves the factors of production/us. This is the fundamental of capitalistic system, and the essential feature of market mechanism is price signal. Example: Block Buster goes out of business, start downloading through netflix. Laissez faire-leave it alone (hands off, capitalistic society). How do we compete? Produce least cost method and produce. Who? For those who want it and the ability to purchase it (capitalism). This is what makes America great. Karl Marx emphasized how free markets tend t concentrate wealth and power in the hands of the few, at the expense of the many. In other words, few in the top and bottom - has worked- incentives are gone - you don’t keep anything - you get what the government gives you. J. Keynes, government intervention...
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...Electronic copy available at: http://ssrn.com/abstract=1067441 1 Vision into Action: Infosys Technologies Arpita Saha1 Abstract: Infosys is one of the world¡¦s most respected companies. It is one of those companies which have changed the way India is perceived in the global purview. Since its inception Infosys¡¦ founder members shared the vision of becoming a globally recognized organization providing high quality business solutions. Infosys is regarded as a highly respected organization because of the set of values which drive them; like the integrity and transparency with which they conduct themselves, their customer friendliness and their exemplary leadership. This article delves into the company¡¦s growth path and the role played by their vision and mission in their progress. Introduction Infosys is the world leader in providing high quality Information Technology and software services to its clients globally. Infosys is one of the companies which spearheaded the software services outsourcing strategies. Offshore outsourcing is a process in which an external organization is contracted to execute some task in an outside territory. And this has several advantages for the organizations which outsource. Infosys delivers offshore IT and software services like infrastructure support, application development, IT consulting, re-engineering and other services like setting up software development centers at different locations for their clients. Adding another feather...
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...Many Americans across the United States are faced with income inequality. These income inequalities have many negative effects on communities and neighborhoods. These income inequalities also have a couple positives changes as well. Only time will tell how the economic state of the middle class and lower classes will improve or continue to fall into harder times. Johnson and Rhodes state “where you live clearly affects how you grow up”, which is absolutely true (p. 387)! Those that live in poverty may also deal with school systems and other institutions such as clinics that don’t have enough funding to go around. The wealth distribution has been a continuous problem that has no simple answer, what once may have seemed like a private trouble...
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...V Present-V PastV PastN ×100 where V Present is present or future value, V Past is past or present value and N equivalent to the number of years (Parker, 2002). Hence the growth rate of 1960-1969 is calculated as follows: Population Growth Rate 1960-1969= 20,009,140-18,406,900V Past10 = 0.87% The calculation proceeds with the 1970-1979, 1980-1989, 1990-1999, and lastly, 2000-2012 population growth rates, and final figure taken is the average of these 5 rates. Table 1 – Population Growth Rate (1960-2012) and Real GDP Per Capita in 2012 (USD) of 20 Developing Countries with high population growth rates in the early century (Source adopted from IndexMundi, 2013 Table 2 – Population Growth Rate (1960-2012) and Real GDP Per Capita in 2012 (USD) of 20 Developing Countries with high low population growth rates in recent years (Source adopted from IndexMundi, 2013) The following scatter plot is constructed using the approximate data specified in both the tables above. The graph shows the relationship of population growth and GDP per capita in 40 of these...
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...tax in 1861 to fund Civil War * Repealed in 1865 * Income tax law passed in 1894 but rejected by Supreme Court * 16th amendment was passed in 1913 * 42% of revenue is raised from individual income tax * 40% from social security, 9% corporate income tax, 9% other Tax Structure: * Progressive tax structure: tax rate increases as the tax base increases * US income tax system is this way * Proportional tax structure (flat tax): tax rate remains the same regardless of tax base * Regressive tax structure: tax rate decreases as the tax base increases * Social security tax system is this way * Average tax rate: total tax paid on a certain amount of taxable income * Marginal tax rate: rate of tax paid on the highest dollar of income Calculation of Tax: Income - deductions = taxable income X tax rates = tax liability - tax payments/credits = tax refund or due with return * For TI up to $100,000 use tax tables * Use tax rate schedules for higher income * Tax rate tables are calculated at midpoint of range; rate schedules are precise Tax Forms: * 1040EZ must be: * Single or married filing jointly * Taxable income less than $100,000 * Have no dependents * May only have income from wages, unemployment and interest * 1040A must be: * Any of 5 filing statuses and have dependents * Income limited to $100,000 * May have more interest, dividends...
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...January 2015 Research Institute Thought leadership from Credit Suisse Research and the world’s foremost experts Emerging Consumer Survey 2015 EMERGING CONSUMER SURVEY 2015_2 Contents 03 Editorial 04 The emerging consumer in 2015 12 A sum of different parts 20 e-Commerce and the emerging consumer 30 Focus on travel 36 Focus on autos 40 Focus on healthcare 46 Brands and the emerging consumer in 2015 62 Brazil: Steady decline continues 64 China: A life online 66 India: New government, strong consumer 68 Indonesia: An under-penetrated market 70 Mexico: Structural potential, cyclical hurdles 72 Russia: Dark clouds gather 74 Saudi Arabia: The petro-dollar 76 South Africa: Reduced optimism 81 About the survey 83 Imprint / Disclaimer For more information, please contact: Richard Kersley, Head of Global Securities Products and Themes, Credit Suisse Investment Banking, richard.kersley@credit-suisse.com Michael O’Sullivan, Chief Investment Officer UK & EMEA, Credit Suisse Private Banking & Wealth Management, michael.o’sullivan@credit-suisse.com COVERPHOTO: ISTOCKPHOTO.COM/XAVIERARNAU, PHOTO: ISTOCKPHOTO.COM/ALIJA 78 Turkey: Subdued but stable EMERGING CONSUMER SURVEY 2015_3 Editorial We are delighted to publish the fifth edition of the Credit Suisse Research Institute’s “Emerging Consumer Survey.” To undertake the project, we have again partnered with global market research firm Nielsen, which has conducted...
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