Books
Summary
We are well aware of the rise of the 1% as the rapid growth of economic inequality has put the majority of the world’s wealth in the pockets of fewer and fewer. One much-discussed solution to this imbalance is to significantly increase the rate at which we tax the wealthy. But with an enormous amount of the world’s wealth hidden in tax havens in countries like Switzerland, Luxembourg, and the Cayman Islands this wealth cannot be fully accounted for and taxed fairly. No one, from economists to bankers to politicians, has been able to quantify exactly how much of the world’s assets are currently hidden until now. Gabriel Zucman is the first economist to offer reliable insight into the actual extent of the world’s money held in tax havens. And it’s staggering. In The Hidden Wealth of Nations, Zucman offers an inventive and sophisticated approach to quantifying how big the problem is, how tax havens work and are organized, and how we can begin to approach a solution. His research reveals that tax havens are a quickly growing danger to the world economy.
In the past five years, the amount of wealth in tax havens has increased over 25% there has never been as much money held offshore as there is today. This hidden wealth accounts for at least $7.6 trillion, equivalent to 8% of the global financial assets of households. Fighting the notion that any attempts to vanquish tax havens are futile, since some countries will always offer more advantageous tax rates than others, as well the counter-argument that since the financial crisis tax havens have disappeared, Zucman shows how both sides are actually very wrong. In The Hidden Wealth of Nations he offers an ambitious agenda for reform, focused on ways in which countries can change the incentives of tax havens. Only by first understanding the enormity of the secret wealth can we begin to estimate the kind of actions that would force tax havens to give up their practices. Zucman’s work has quickly become the gold standard for quantifying the amount of the world’s assets held in havens.
In this concise book, he lays out in approachable language how the international banking system works and the dangerous extent to which the large-scale evasion of taxes is undermining the global market as a whole. If we are to find a way to solve the problem of increasing inequality, The Hidden Wealth of Nations is essential reading.
Reviews
“Zucman’s work on tax havens is the first serious economic research in this area. His evaluation of the share of global household wealth that is located in tax havens has become the standard in the profession. Most importantly, this is the first work offering credible estimates of the kind of economic sanctions that would make tax havens give up the financial opacity that allows them to prosper. The conclusions are powerful.” — Thomas Piketty, author of Capital in the Twenty-First Century
“Zucman seems to have little ambivalence about how to interpret the data, as his book is subtitled The Scourge of Tax Havens. He acknowledges that some view tax havens as perfectly legal and legitimate. But whatever the politics, for anyone who cares about understanding the economy, it’s clear a dramatic shift is under way.” ― Wall Street Journal
“With his book, The Hidden Wealth of Nations, Zucman is positioning himself as this year’s Piketty, whose opus renewed a debate about inequality last year. . . . There has never been as much wealth sitting in tax havens as there is today, Zucman says, whether it’s Apple Inc. funneling billions in profits through a tiny Irish unit or a French cabinet minister using secret accounts to cheat on his taxes. . . . What is to be done? Zucman said there needs to be a central global register of the owners of the world’s wealth, similar to various registries for real estate holdings. Such a database doesn’t have to be public, but it must be available to regulators.” ― Bloomberg Business News
Summary
International Tax Primer provides an accessible and comprehensive guide to the fundamental aspects of international taxation with an introduction to the policies that countries seek to advance with their international tax rules. Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Developments (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive and continuing issues concerning the digital economy.
What In This Book
The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following with an extensive glossary of international tax terms:
- role of the tax adviser in planning international transactions;
- taxation of residents on foreign income and of nonresidents on domestic income;
- mechanisms used to mitigate the risks to taxpayers of international double taxation;
- transfer pricing rules to prevent the avoidance of tax by multinational corporations;
- anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities;
- overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and
- challenges posed by taxation of income derived from the digital economy.
Summary
Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs).
DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers.
Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020.
Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom.
What’s new in this edition?
There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries.
What In This Book
You’ll find:
- Reports about major features in the DTC practice of many leading jurisdictions, such as:
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- the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US
- Sections on divergent country practice covering their national models and networks of bilateral DTCs
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- Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice
- Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument
- Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries
This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs.
On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences.
Summary
Although the details of tax law are literally endless—differing not only from jurisdiction to jurisdiction but also from day-to-day—structures and patterns exist across tax systems that can be understood with relative ease. This book, now in an updated new edition, focuses on these essential patterns. It provides an immensely useful introduction to the core common knowledge that any well-informed tax lawyer or policy maker should have about comparative tax law in our times. The busy reader will welcome the compact nature of this work, which is shorter than the first edition and can be read in a weekend if one skips footnotes.
The authors elucidate the commonalities and differences across countries in areas including (much of the detail new to the second edition):
- general anti-avoidance rules;
- court decisions striking down tax laws as violating constitutional rules against retroactivity, unequal treatment of equals, confiscation, and undue vagueness;
- statutory interpretation;
- inflation adjustment rules and the allowance for corporate equity;
- value added tax systems;
- concepts such as “tax”, “capital gain”, “tax avoidance”, and “partnership”;
- corporate-shareholder tax systems;
- the relationship between tax and financial accounting;
- taxation of investment income;
- tax authorities’ ability to obtain and process information about taxpayers; and
- systems of appeals from tax assessments.
The information and analysis pull together valuable material, which is scattered over a disparate literature, much of it not available in English.
Especially considering the dynamic nature of tax law, whose rate of change exceeds that of any other field of law, the authors’ clear identification of the underlying patterns and fundamental structures that all tax systems have in common—as well as where the differences lie—guides the reader and offers resources for further research.
What In This Book
You’ll find:
- inflation adjustment rules and the allowance for corporate equity;
- value added tax systems;
- concepts such as “tax”, “capital gain”, “tax avoidance”, and “partnership”;
- corporate-shareholder tax systems;
- the relationship between tax and financial accounting;
- taxation of investment income;
Summary
From the Preface:
This TRM™ tax-Radar™ seven steps special report is based on over 120 lectures presented to many multinational corporations (MNEs) and smaller businesses (SMEs) looking to minimize one of the largest financial risks facing them: tax.
It looks at where they have failed to properly recognize the potential tax exposure they face. The case studies in this special report are very real and based on years of experience. The names, places, and specific details are not, so as to preserve the secrecy of the taxpayers.
One thing this special report will do for you is teach and guide you, step by step, that in matters of tax it is extremely dangerous not to be proactive. No matter what anyone says, tax is always and will always remain a large expense for any successful business. States will always look to their most successful taxpayers to collect 80% of the tax from the 20% most successful taxpayers. It makes commercial sense. The balance of tax officials’ time will most probably be spent chasing after tax criminals, those who are blatant tax evaders and offenders. For you, who are reading this special report, I doubt you fall into this latter category; otherwise you would only have grabbed this special report if its title read How to Evade Tax, Legally!
IRSs around the world want to know that their actual cash flows from taxpayers are stable. A good guess is that about 20% of all taxpayers are those whom they rely on the most. If these 20% of taxpayers have devised a TRM™ process to ensure ongoing transparency and compliance through a self-audit process, the costs of collection and the costs of compliance are equally reduced, with an accurate result.
Disputes that may emerge will be limited to differences of opinion and interpretation where taxpayers have embarked on proactive tax planning, as opposed to arguing about shoddy unknown tax pitfalls. Now it is for you to read on and open the door to proactive tax risk management (TRM™) and manage effectively one of the biggest financial risks in your business.
Prof. Daniel N. Erasmus
Jupiter, Florida, USA
Reviews
I have known Daniel for many years now and his approach is quite unique and refreshing. He focuses on the key issues and ensures that even though certain issues are controversial he calls it by name and deals with it. Worth a read, will get you thinking again. — Renier
A very inspiring piece of work, which stimulates forward-thinking and strategic planning. The excellent but practical approach to the principles of Tax Risk Management in the form of checklists, diagrams and a provocative Tax Query Questionnaire, makes this a useful guide to be applied in basic as well as complex tax environments. The fresh insights displayed will be a welcome addition to any tax, risk management or strategic planning library. —Anonym
