Author: Russell K. OsgoodPublisher:
ISBN:
Category : Aliens
Languages : en
Pages :
Book Description
Cases, Materials, and Problems on United States Taxation of Foreign Income and Foreign Persons
Author: Russell K. OsgoodPublisher:
ISBN:
Category : Aliens
Languages : en
Pages :
Book Description
Introduction to United States International Taxation
Author: James R. RepettiPublisher: Kluwer Law International B.V.
ISBN: 9403523905
Category : Law
Languages : en
Pages : 458
Book Description
The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.
Aspen Treatise for Introduction To United States International Taxation
Author: James R. RepettiPublisher: Aspen Publishing
ISBN: 1543827241
Category : Business & Economics
Languages : en
Pages : 369
Book Description
The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
United States Taxation of Foreign Income and Foreign Persons
Author: Foreign Tax I
Author: Harvey P. DalePublisher:
ISBN:
Category : Aliens
Languages : en
Pages : 600
Book Description
U.S. International Taxation
Author: Reuven Shlomo Avi-YonahPublisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 684
Book Description
Avi-Yonah, Ring and Brauner's U.S. International Taxation, Cases and Materials provides law teachers with an easy-to-use casebook to teach U.S. international taxation. Because of the complexity of the field, the authors focus on the essentials and explore: How U.S. tax law treats foreign investors deriving income from sources within the United States (inbound transactions) How the law treats U.S. taxpayers deriving foreign source income (outbound transactions) How details of the tax law fit into a broader structure Students are encouraged to fit specific issues into a larger context so they can develop an intuition for where problem areas may lie.
Federal Income Tax Project
Author: American Law InstitutePublisher:
ISBN:
Category : Law
Languages : en
Pages : 546
Book Description
Proposals on United States taxation of foreign persons and of the foreign income of United States persons.
A Practical Guide to U. S. Taxation of International Transactions
Author: Robert MeldmanPublisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 408
Book Description
Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
Author: 
Author: Boris I. Bittker