July 2017  
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Bulletin for International Taxation
 
This free e-mail service informs you about the contents of the forthcoming edition of Bulletin for International Taxation.

Issue No. 7 - 2017 of the Bulletin for International Taxation is now available online.

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Conference
71st Congress of the International Fiscal Association
27 August-1 September 2017,
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Number 7 - 2017 contains the following:
ARTICLES

International/OECD

Should Developing Countries Include Article 7 in Their Tax Treaties?

Sergio André Rocha

In this article, the author discusses a new model for taxing business profits and maintains that the United Nations’ mission to develop a fairer system for the allocation of taxing rights between developed and developing countries must be fulfilled.

International/OECD

The Transfer Pricing Aspects of Cross-Border Performance Guarantees

Gaurav Deshpande

This article considers the transfer pricing aspects of cross-border performance guarantees and the various issues to which the payment of fees associated with such guarantees give rise.

European Union/OECD

The European Union’s Ambition to Harmonize Rules to Counter the Abuse of Member States’ Disparate Tax Legislations

Caroline Docclo

The Council Directive (2016/1164) will affect taxpayers’ transactions within the European Union but also beyond the EU territory. This article describes its rules to counter the abuse of the tax legislations of EU Member States, in light of the political discussions that led to its final provisions.

Hong Kong/United States

Is Taxpayer Privacy Being Compromised in Hong Kong?

Belinda Law

This article examines the protection of privacy for Hong Kong taxpayers and the extent to which taxpayer privacy is being compromised as financial institutions are forced to comply with the US Foreign Account Tax Compliance Act and, more recently, the Standard for Automatic Exchange of Financial Account Information in Tax Matters.

United States

Procedural Issues of Human Rights and Taxation: Access to Justice

Peter J. Panuthos

The US government as well as public and private organizations, such as law schools and legal services organizations, strive to ensure that the rights of all taxpayers are protected in administrative and judicial proceedings. In this article, the author discusses some of these measures in the context of the IRS appeals process, the Tax Court litigation process, judicial independence and provision of counsel to self-represented petitioners.

China (People’s Rep.)/United States

Why No Corporate Tax Inversions to China?

James G.S. Yang and Huanyu Ouyang

Many US corporations have moved abroad, but none to China. This article reveals that both the United States and China have high tax rates. The United States offers a tax deferral on undistributed foreign earnings, but not China. China, therefore, has the worst of both worlds.

International

Report of the Proceedings of the Seventh Assembly of the International Association of Tax Judges Held in Madrid on 30 September and 1 October 2016

Bob Michel

This report summarizes the proceedings of the Seventh Assembly of the International Association of Tax Judges, which was held in Madrid on 30 September and 1 October 2016.

Available online only.

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