T536 Taxation Of Trans-Pacific Transactions
Jeffery KadetAn introduction to practicing taxes internationally with a principal geographical focus on the Asia-Pacific region with particular emphasis on investments into and cross-border transactions with China, Japan, and other countries in the region. The practice of international taxation requires a combination of both knowledge and mental processes. Knowledge includes international tax principles and me... more
| Publishes | Daily | Episodes | 25 | Founded | 15 years ago |
|---|---|---|---|---|---|
| Category | News | ||||
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Latest Episodes
Audio Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897 (0:00), and (ii) Tax Treaty Articles 7 (4:03), 8 (57:38), 9 (1:01:00), 10 – 12 (1:05:18), 21 (1:38:47), 13 (1:41:55), and 15 (1:45:35).
Audio Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan/US tax teaty (0:00), and (ii) Tax Treaty Articles 5 (4:56) and 6 (1:40:07).
Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1 – 4 (0:00), and (ii) initial discussion on Article 5 (1:45:06).
Audio Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities" (0:00), and (ii) Value Added Tax (1:13:46).... more
Audio Session 6: (i) General Anti-Avoidance Rules/Substance vs Form (0:00), and (ii) transfer pricing (1:14:38). For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structur... more
Audio Session 5: (i) Local Entity Participation Requirements (0:00), (ii) Tax Effective Locations (13:06) including discussion of the Indo-Foods Case (1:35:23), and (iii) Discussion of ABC Case Study Facts and implications thereof (1:54:19).
Audio Session 4: (i) Forms of Doing Business in Another Country (0:00), (ii) Consolidated vs Separate Entity Taxation (1:03:47), (iii) Governmental Incentives including Tax Sparing (1:24:29), and (iv) Discussion of Khoo Holdings Case (1:54:50).
Audio Session 3: (i) Jurisdiction Case (0:00), (ii) Residency and Basis of Taxation (19:25), (iii) Classes of Income and Source (52:11), (iv) Elimination of Double Taxation (1:29:33), (v) Khoo Holdings Case (2:10:57), and (vi) ABC Case (2:13:55).
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