Hearing Before the Committee on Foreign Relations United States Senate
| Preis: | 12.95 EUR* (inkl. MWST zzgl. Versand - Preis kann jetzt höher sein!) |
| Versand: | 0.00 EUR Versandkostenfrei innerhalb von Deutschland |
| Partner: | buecher.de |
| Hersteller: | Forgotten Books (Author, Unknown) |
| Stand: | 2015-08-04 03:50:33 |
Produktbeschreibung
Excerpt from Hearing Before the Committee on Foreign Relations United States Senate: One Hundred Third Congress, First Session, October 27, 1993 It appears that all four dozen and their relatives have appeared at this hearing room this morning. This is a very, very difficult and complicated issue. The reason I am here, Mr. Chairman, is I do not want us to proceed with additional tax treaties with other countries without addressing the question of how we apportion or divide income between the countries in which a multinational business does business. We are told ad nauseam these days that this is increasingly a global economy. I understand that. More and more companies are doing business worldwide. The question then becomes what portion of their income is attributable to the various countries in which they do business. At the State government level we have had to confront that question before, and have done it with a fair amount of success. We have had to develop a formulary approach to try and divide up corporation´s income into reasonable pieces, among the states in which that corporation operates. This serves to protect the businesses so they are not overtaxed in the multiplicity of jurisdictions in which they do business. It also protects the respective jurisdictions so that there is not massive underreporting of income. At the Federal level, by contrast, we have done something different. We have continued to use an antiquated approach called the arm´s-length method, in which we look at related corporations, related parties, and try to reconstruct the pricing structure in transactions between them and therefore how much income the parties earned in one country or another. The fact is, the "arm´s-length method" is like using a buggy whip with today´s automobiles. It does not work. It is antiquated. It is not useless, but close to useless. And I do not want to see tax treaties proceed that chain ourselves to that same tired failure. Now, let me use the Mexican treaty as an example. I believe, section 9, article 9 of this treaty, talks about comparable pricing methodology. The Treasury Department has consistently ruled that the arm´s length or comparable pricing methodology will preclude a formulary approach. That is our Government´s position, our formal position. We say in these treaties that we will use comparable pricing methodologies, which is the arm´s-length approach. As we move this treaty through the Congress, I want, to include a simple provision that indicates in article 9 that a formula approach is not prohibited, that is that this treaty does not prohibit a formula approach if comparative pricing - the arm´s-length standard - does not work. Now, how do we accomplish that? Well, there are a number of ways. I understand that some parties to these treaties would not like it, but there are ways of accomplishing it. And I will, Mr. Chairman, talk with you and other committee members about perhaps a so-called understanding that might trail with the legislation, or some other device. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
* Preis kann jetzt höher sein. Den aktuellen Stand und Informationen zu den Versandkosten finden sie auf der Homepage unseres Partners.
Folgende Produkte könnten dir ebenso gefallen
