Federal Taxation of Income, Estates, and Gifts PDF Download

Author: Boris I. Bittker
Publisher: Warren Gorham & Lamont
ISBN:
Category : Gifts
Languages : en
Pages : 852

View

Book Description
Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.

Author: Arvid Aage Skaar
Publisher: Kluwer Law International B.V.
ISBN: 9403520647
Category : Law
Languages : en
Pages : 999

View

Book Description
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.

Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Individual retirement accounts
Languages : en
Pages : 284

View

Book Description

Author: CCH Incorporated Staff
Publisher:
ISBN: 9780808002543
Category : Business & Economics
Languages : en
Pages : 1822

View

Book Description

Author: Israel Blumenfrucht
Publisher:
ISBN: 9780155352872
Category :
Languages : en
Pages : 76

View

Book Description

Author: Judith A. Sage
Publisher: Prentice Hall
ISBN: 9780133403817
Category : Business & Economics
Languages : en
Pages : 1256

View

Book Description
A comprehensive introduction to federal taxation covering individuals, partnerships, and corporations.

Author: JEFFREY L. KWALL
Publisher: Foundation Press
ISBN: 9781640207516
Category :
Languages : en
Pages : 500

View

Book Description
On the 25th anniversary of Jeffrey Kwall's groundbreaking The Federal Income Taxation of Corporations, Partnerships, Limited Liability Companies, and Their Owners (now in its 6th edition), Kwall has done it again with a brand-new take on personal income tax in The Federal Income Taxation of Individuals: An Integrated Approach. Part of Foundation Press's forward-looking Doctrine and Practice Series, Kwall's book offers a modern approach to income tax designed to resonate with the current generation of law students. The book fully integrates the Tax Cuts and Jobs Act of 2017 and, in addition to the traditional cases, contains a collection of contemporary cases with provocative fact patterns that will interest all students. In that light, the book was designed to accommodate students with different learning styles by providing explanatory text and notes, detailed examples and problems, and a myriad of text boxes offering insights, discussion questions, online references, points worth noting, and applications to the practice of law. A primary goal of the book is to expose students to practical tax problems and to heighten student awareness of quality of practice issues. This goal dovetails with the book's recurring theme that economic considerations always outweigh tax considerations. The book consists of 18 Chapters. After an Introduction (Chapter 1), Chapters 2-8 focus on Gross Income. Because tax law is a foreign subject to most law students, these early chapters explore gross income in the context of familiar economic relationships (e.g., a business owner and its employees, a donor and a donee, a lender and a borrower). Chapters 9 and 10 address Deductions. In addition to focusing on allowance provisions, these chapters integrate the consequential impact of classifying deductions as section 62 deductions, miscellaneous itemized deductions, and other itemized deductions. Chapters 11-14 are focused on Timing questions with emphasis on the tax law's treatment of time value of money issues. Chapters 15 and 16 address Tax Rates and include coverage of assignment of income issues, capital gains and losses, and dividends. Chapter 17 highlights the Alternative Minimum Tax and Chapter 18 introduces the taxation of corporations and partnerships to whet students' appetites for future tax courses. The book is ideally suited for a three-credit or four-credit introductory income tax course.

Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 12

View

Book Description

Author: John O. Everett
Publisher: Houghton Mifflin Harcourt P
ISBN: 9780155352803
Category : Income tax
Languages : en
Pages : 1072

View

Book Description

Author:
Publisher:
ISBN:
Category : American literature
Languages : en
Pages : 2118

View

Book Description