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The article comments on Sections 864(c)(8) and 1446(f) as added to the Internal Revenue Code of 1986 by Public Law 115-97 on December 22, 2017. Issues discussed are computation of gain or loss, interaction with income tax treaties, effect of the Foreign Investment in Real Property Tax Act (FIRPTA) publicly traded partnership exception, procedures for withholding and deposit of tax, certification procedures regarding foreign or domestic status of transferor, and tiered partnerships.

The reflections of tax competition in Turkey and six Eurepean Union countries covering the years of 2000-2013 is analysed in this paper. In this context, whether the relationship between corporation income tax and foreign direct investment is analysed with panel data methods. As a result of analysis, the negative relationship between the corporation income tax and foreign direct investment is determined. [ABSTRACT FROM AUTHOR]

This paper analyzes the main tax consequences for the foreigners that invests in Colombia through a commercial trust agreement. Depending on the purpose and the structure of the business, for purposes of the Colombian foreign exchange regime, the investment will qualify either as portfolio or as foreign direct investment, certainly, the tax effects for the investor will depend on the type of investment. Primarily, the investor must take into account several aspects of the Colombian tax regulation regarding foreigners taxation, which will be the framework to identify how will be taxed the profit or the capital gain that may arise from the investment, on the other hand, it must be understood the tax effects of the type of investment, i.e. those derived from the direct or the portfolio investment. [ABSTRACT FROM AUTHOR]

This article presents legislative developments in international taxation in Canada and features several tax firms and advisers in the country as of September 2005. A review of Canadian tax developments for the past year highlighted three legislative developments: the introduction of a package of draft technical amendments to the Income Tax Act; proposed legislation to provide for a cap on deductibility of losses derived from interest and other expenses; and proposals for the taxation of foreign investment entity participation and of non-resident trusts. Leading tax firms in Canada Davies Ward Philips & Vineberg, Ostler Hoskin & Harcourt, Ernst & Young; and KPMG.

The paper analyses state-contingent taxation of the return to foreign investment in a country. It is assumed that the investment will be undertaken only if the investor obtains a given expected utility from the project. The optimal tax schedule across income levels in different states is characterized in cases where private domestic income is exogenous and in the case of endogenous domestic taxation. In the latter case the striking results are obtained that the total tax revenue should always increase when total income increases, and it makes no difference for the rate of increase whether it is domestic or foreign income that increases. [ABSTRACT FROM AUTHOR]

ABSTRACT: This study investigates the influence of both the state corporate income tax rate and the form of the income tax base structure on foreign investment in manufacturing assets. An econometric model of foreign investment is derived from a supply-oriented theory of regional investment, That is, the decision to develop productive capacity in one region as opposed to another is due to regional advantages. Empirical results suggest that tax structures that use the unitary method of accounting have a substantial impact on the amounts of foreign investment. On the other hand, business income tax rates appear to have little impact. [ABSTRACT FROM AUTHOR]

The article reports on the opening of the Shenzhen-Hong Kong Stock Connect on December 5, 2016. Topics discussed include trading of selected A-shares listed on the Shenzhen Stock Exchange (SSE) via the Hong Kong Stock Exchange, the Shanghai-Hong Kong Stock Connect mechanism, and the temporary exemptions from Chinese income taxes and value added tax for trading gains arising to foreign investors on SSE-listed shares.

The article reports on the four-phase strategy implemented by the U.S. Internal Revenue Service (IRS) for increasing withholding of income taxes on payments to foreign persons. It states that under the industry issue focus programme, the IRS large and midsize business (LMSB) has three separate compliance tier designations for issues it considers important. It mentions that tier I issues are considered significant and can impact one or more industries. Under the Internal Revenue Code (IRC), U.S. persons who make payments of certain types of U.S.-source income to non-residents are subject to withhold tax at a rate of 30% on such payments, unless there are exemptions or applicable treaty provisions allowing for a rate reduction.

The article discusses the developments in the area of taxation in Vietnam as of mid-2013. It claims that the country has signed double taxation agreements (DTA) with over 60 countries in order to eliminate double taxation of international income and promote foreign direct investment. It examines the various official rulings issued by the General Department of Taxation (GDT) concerning such issues related to the so called permanent establishment (PE).

The article discusses the imposition of tax incentives for foreign investments in Bosnia and Herzegovina. The incentives offer same rights and obligations to both foreign and domestic investors. The government also introduces corporate income tax reduction against a foreign profit tax paid by investors.

The article reports that the Australian government committed itself to a comprehensive review of Australia's tax system to create a tax structure that positions it to deal with the demographic, social, economic and environmental challenges of the 21st century. The government has quarantined three issues from the review, including the Goods and Services Tax (GST) regime, tax-free superannuation payments for over 60s, and the announced aspirational goals for personal income tax. More recently, the Review of International Tax Arrangements (RITA) reviewed those international tax laws affecting offshore investment, the attraction of capital and related matters.