Controversial Topics In International Taxation: U.S.A., OECD & Brazil. Tax Policy in the Attraction of Foreign Investments

      Аннотация: Leonardo Castro is a tax lawyer and international tax consultant admitted to practice law in Brazil, currently based in S?o Paulo city. He has 10 years of practical experience in tax & corporate legal matters obtained at prestigious law firms in New York City, S?o Paulo and Rio de Janeiro. His main areas of experience are international taxation, transfer pricing, tax planning (inbound & outbound), M&A tax, customs & duties and private wealth planning. This book is the result of the ten most important articles written by him in English out of almost 100 published, several of them awarded with International Prizes from notorious associations and institutions, such as the International Bar Association (IBA) and the Transnational Taxation Network (TTN). These published papers deal with the most important subjects in the modern economy of every developed and developing country, since they relate to the international tax policy and interpretation of international tax rules for foreign investors worldwide, being that in regard to the statues and models of the United States, OECD and Brazil.

Ключевые слова: international, tax, Law, Brazil, OECD, United States, Transfer Pricing, Treaties, foreign, investment, planning, CFC, GAAR, ANTI AVOIDANCE