Double taxation occurs when the same income is taxed in two different countries under each country's tax rules. Bilateral relief agreements (also known as double taxation avoidance agreements or tax treaties) are entered into between two countries to provide relief from double taxation. These agreements typically use either the exemption method, which exempts the income in one country, or the tax credit method, which allows the country of residence to credit taxes paid in the source country. Unilateral relief is provided by some countries for their residents who pay foreign tax in countries they do not have a bilateral agreement with. The goal of these relief methods is to promote free international trade and investment by reducing double taxation.
International Business Transactions has indeed made the world smaller and more developed. However due to the free cross boundary transactions, business entities are now able to generate revenue and not pay the appropriate taxes in their respective countries.
The G20 Countries had assigned OECD to come up with some non tax evasion rules so that the countries of the world may accept the same without any dispute.
This presentation covers the BEPS Rules suggested by OECD and explains the changes in Tax Laws that India has incorporated in order to align with BEPS and to curb Tax Evasion.
This presentation was performed by my GMCS Team during the GMCS 2 Course at Mangalore Branch of SIRC of ICAI.
Cleaning Up Your Tax with Voluntary Disclosure AgreementsCBIZ, Inc.
While paying taxes might not be our favorite pastime, the overwhelming majority of taxpayers strive to file and pay all of their tax obligations. However, sometimes taxpayers' best efforts to comply with their tax obligations are not enough, especially in the state and local tax world. Although it may be an innocent mistake, such non-compliance may be very costly if it is first discovered by the state or local taxing jurisdiction, because the taxpayer will not only be subject to tax and interest but also harsh penalties (up to 25 percent or more).
International Business Transactions has indeed made the world smaller and more developed. However due to the free cross boundary transactions, business entities are now able to generate revenue and not pay the appropriate taxes in their respective countries.
The G20 Countries had assigned OECD to come up with some non tax evasion rules so that the countries of the world may accept the same without any dispute.
This presentation covers the BEPS Rules suggested by OECD and explains the changes in Tax Laws that India has incorporated in order to align with BEPS and to curb Tax Evasion.
This presentation was performed by my GMCS Team during the GMCS 2 Course at Mangalore Branch of SIRC of ICAI.
Cleaning Up Your Tax with Voluntary Disclosure AgreementsCBIZ, Inc.
While paying taxes might not be our favorite pastime, the overwhelming majority of taxpayers strive to file and pay all of their tax obligations. However, sometimes taxpayers' best efforts to comply with their tax obligations are not enough, especially in the state and local tax world. Although it may be an innocent mistake, such non-compliance may be very costly if it is first discovered by the state or local taxing jurisdiction, because the taxpayer will not only be subject to tax and interest but also harsh penalties (up to 25 percent or more).
Acetabularia Information For Class 9 .docxvaibhavrinwa19
Acetabularia acetabulum is a single-celled green alga that in its vegetative state is morphologically differentiated into a basal rhizoid and an axially elongated stalk, which bears whorls of branching hairs. The single diploid nucleus resides in the rhizoid.
Read| The latest issue of The Challenger is here! We are thrilled to announce that our school paper has qualified for the NATIONAL SCHOOLS PRESS CONFERENCE (NSPC) 2024. Thank you for your unwavering support and trust. Dive into the stories that made us stand out!
The French Revolution, which began in 1789, was a period of radical social and political upheaval in France. It marked the decline of absolute monarchies, the rise of secular and democratic republics, and the eventual rise of Napoleon Bonaparte. This revolutionary period is crucial in understanding the transition from feudalism to modernity in Europe.
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June 3, 2024 Anti-Semitism Letter Sent to MIT President Kornbluth and MIT Cor...Levi Shapiro
Letter from the Congress of the United States regarding Anti-Semitism sent June 3rd to MIT President Sally Kornbluth, MIT Corp Chair, Mark Gorenberg
Dear Dr. Kornbluth and Mr. Gorenberg,
The US House of Representatives is deeply concerned by ongoing and pervasive acts of antisemitic
harassment and intimidation at the Massachusetts Institute of Technology (MIT). Failing to act decisively to ensure a safe learning environment for all students would be a grave dereliction of your responsibilities as President of MIT and Chair of the MIT Corporation.
This Congress will not stand idly by and allow an environment hostile to Jewish students to persist. The House believes that your institution is in violation of Title VI of the Civil Rights Act, and the inability or
unwillingness to rectify this violation through action requires accountability.
Postsecondary education is a unique opportunity for students to learn and have their ideas and beliefs challenged. However, universities receiving hundreds of millions of federal funds annually have denied
students that opportunity and have been hijacked to become venues for the promotion of terrorism, antisemitic harassment and intimidation, unlawful encampments, and in some cases, assaults and riots.
The House of Representatives will not countenance the use of federal funds to indoctrinate students into hateful, antisemitic, anti-American supporters of terrorism. Investigations into campus antisemitism by the Committee on Education and the Workforce and the Committee on Ways and Means have been expanded into a Congress-wide probe across all relevant jurisdictions to address this national crisis. The undersigned Committees will conduct oversight into the use of federal funds at MIT and its learning environment under authorities granted to each Committee.
• The Committee on Education and the Workforce has been investigating your institution since December 7, 2023. The Committee has broad jurisdiction over postsecondary education, including its compliance with Title VI of the Civil Rights Act, campus safety concerns over disruptions to the learning environment, and the awarding of federal student aid under the Higher Education Act.
• The Committee on Oversight and Accountability is investigating the sources of funding and other support flowing to groups espousing pro-Hamas propaganda and engaged in antisemitic harassment and intimidation of students. The Committee on Oversight and Accountability is the principal oversight committee of the US House of Representatives and has broad authority to investigate “any matter” at “any time” under House Rule X.
• The Committee on Ways and Means has been investigating several universities since November 15, 2023, when the Committee held a hearing entitled From Ivory Towers to Dark Corners: Investigating the Nexus Between Antisemitism, Tax-Exempt Universities, and Terror Financing. The Committee followed the hearing with letters to those institutions on January 10, 202
2024.06.01 Introducing a competency framework for languag learning materials ...Sandy Millin
http://sandymillin.wordpress.com/iateflwebinar2024
Published classroom materials form the basis of syllabuses, drive teacher professional development, and have a potentially huge influence on learners, teachers and education systems. All teachers also create their own materials, whether a few sentences on a blackboard, a highly-structured fully-realised online course, or anything in between. Despite this, the knowledge and skills needed to create effective language learning materials are rarely part of teacher training, and are mostly learnt by trial and error.
Knowledge and skills frameworks, generally called competency frameworks, for ELT teachers, trainers and managers have existed for a few years now. However, until I created one for my MA dissertation, there wasn’t one drawing together what we need to know and do to be able to effectively produce language learning materials.
This webinar will introduce you to my framework, highlighting the key competencies I identified from my research. It will also show how anybody involved in language teaching (any language, not just English!), teacher training, managing schools or developing language learning materials can benefit from using the framework.
Palestine last event orientationfvgnh .pptxRaedMohamed3
An EFL lesson about the current events in Palestine. It is intended to be for intermediate students who wish to increase their listening skills through a short lesson in power point.
A Strategic Approach: GenAI in EducationPeter Windle
Artificial Intelligence (AI) technologies such as Generative AI, Image Generators and Large Language Models have had a dramatic impact on teaching, learning and assessment over the past 18 months. The most immediate threat AI posed was to Academic Integrity with Higher Education Institutes (HEIs) focusing their efforts on combating the use of GenAI in assessment. Guidelines were developed for staff and students, policies put in place too. Innovative educators have forged paths in the use of Generative AI for teaching, learning and assessments leading to pockets of transformation springing up across HEIs, often with little or no top-down guidance, support or direction.
This Gasta posits a strategic approach to integrating AI into HEIs to prepare staff, students and the curriculum for an evolving world and workplace. We will highlight the advantages of working with these technologies beyond the realm of teaching, learning and assessment by considering prompt engineering skills, industry impact, curriculum changes, and the need for staff upskilling. In contrast, not engaging strategically with Generative AI poses risks, including falling behind peers, missed opportunities and failing to ensure our graduates remain employable. The rapid evolution of AI technologies necessitates a proactive and strategic approach if we are to remain relevant.
Honest Reviews of Tim Han LMA Course Program.pptxtimhan337
Personal development courses are widely available today, with each one promising life-changing outcomes. Tim Han’s Life Mastery Achievers (LMA) Course has drawn a lot of interest. In addition to offering my frank assessment of Success Insider’s LMA Course, this piece examines the course’s effects via a variety of Tim Han LMA course reviews and Success Insider comments.
1. • Taxation of the same income of the person in
two different countries.
• Such a situation arise due to the countries
following different rules for income taxation.
Double Taxation
2. Globally there are two rules of income
Taxation
Source of
Income
Residential
Rule
3. Source of income:-
• The income is taxed in the country where the
source of such income exist i.e. where the
business establishment is situated, where the
assets/property is located. Whether the
income earner is a resident in that country or
not.
4. Residential rule:-
• The income is taxed on the basis of the
residential status of a person in that country.
Such residential status is determined on various
basis such as
• Place of residence
• Nationality
• Control & management of affairs of business
• Place of incorporation of business
6. Bilateral Relief
Under bilateral relief , the government of two
countries enter into double taxation
avoidance agreement(DTAAs) to provide relief
against such double taxation. These double
taxation avoidance agreement are also known
as “tax treaties”
7. Types of DTAAs
• Comprehensive DTAAs are those which cover
almost all the income covered by any model
convention. Many a time a treaty covers-
wealth Tax
Gift Tax
• Limited DTAAs are those which are limited to
certain type of income only.
8. Why double taxation avoidance
agreement are necessary:-
free flow of international trade and
investment.
Protection against double taxation.
Mutual exchange of information.
It’s legal
10. Methods of relief under DTAAs
sec(90)
Exemption Method
• A particular income is taxed in one country and
exempt in other country.
Tax Credit Method
• The income
according to
is taxed
the treaty
both the countries
and the country of
residence will allow tax credit/ deduction for
the tax charged in the country of source.
11. Unilateral Relief
• Some countries are not in the position to
enter into such agreement with all the
countries. Hence often the country of the
residence provide some tax relief to its
resident persons in respect of their foreign
taxed income.
12. Normal tax provision of unilateral
relief:-
• Eligible person:- only a resident person is
eligible to claim unilateral relief.
• Conditions:-
the income is taxable in India as well as
foreign country because there is no
agreement between these countries.
13. Some practical issue:-
• Dividend distribution tax – no credit of there is
no underlying tax credit.
• Timing and rules of tax filling in both
countries.
• By sharing profits through legal planning into
these subsidiaries.
14. Conclusion
To conclude, we can say that the instrument of
taxation is of great significance on increasing the
level of economic activity and reducing the
income inequalities and help in promoting
economic growth .those who are mitigating to
other countries to earn a living have to pay taxes
in their country of residence as per prevalent tax
laws of the country.