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Author: Peter A. Glicklich Publisher: ISBN: 9781633590304 Category : Aeronautics, Commercial Languages : en Pages :
Book Description
"...discusses the three tax regimes to which nonresident alien individuals and foreign corporations that conduct shipping or air transport activities within the United States may be subject: (1) the general provisions of the Internal Revenue Code of 1986, as amended, for foreign persons with certain modifications; (2) a "reciprocal exemption" provided by [section] 872(b) and [section] 883; or (3) the similar, but separate, exemption available under many U.S. income tax treaties. This Portfolio sets forth in detail the U.S. tax rules applicable under each of the three tax regimes, including in particular the requirements that must be satisfied to qualify for an exemption under either [section] 872(b) and [section] 883 or an applicable U.S. income tax treaty. In this regard, particular emphasis is given to Treasury Regulations issued in 2003 that make it substantially more burdensome for foreign corporations to claim the reciprocal exemption provided by [section] 872(b) and [section] 883."
Author: Peter A. Glicklich Publisher: ISBN: 9781633590304 Category : Aeronautics, Commercial Languages : en Pages :
Book Description
"...discusses the three tax regimes to which nonresident alien individuals and foreign corporations that conduct shipping or air transport activities within the United States may be subject: (1) the general provisions of the Internal Revenue Code of 1986, as amended, for foreign persons with certain modifications; (2) a "reciprocal exemption" provided by [section] 872(b) and [section] 883; or (3) the similar, but separate, exemption available under many U.S. income tax treaties. This Portfolio sets forth in detail the U.S. tax rules applicable under each of the three tax regimes, including in particular the requirements that must be satisfied to qualify for an exemption under either [section] 872(b) and [section] 883 or an applicable U.S. income tax treaty. In this regard, particular emphasis is given to Treasury Regulations issued in 2003 that make it substantially more burdensome for foreign corporations to claim the reciprocal exemption provided by [section] 872(b) and [section] 883."
Author: Guglielmo Maisto Publisher: ISBN: 9789087224035 Category : Aeronautics, Commercial Languages : en Pages : 698
Book Description
This book comprising the proceedings and working documents of an annual seminar held in Milan in November 2016, is a detailed and comprehensive study on the taxation of highly transnational industries engaged in the shipping and air transport sectors. It begins with a comparative analysis of the domestic regulatory and tax regimes of such industries and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union on tonnage taxation systems and VAT regimes. The book then moves to selected tax treaty issues. In particular, it analyses: (i) the historical background and the proposed changes to articles 8 and 15(3) of the OECD Model Convention; (ii) the recent developments concerning article 8 of the OECD Model Convention and the application of the place of effective management criterion, instead of the residence criterion, as connecting factor; (iii) the most relevant tax treaty issues related to the qualification, allocation and apportionment of income derived by shipping and air transport activities; and (iv) the taxation of the remuneration of crews of ships and aircraft. Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices of various states, including Australia, Austria, Brazil, Canada, China and Hong Kong, Denmark, Germany, Greece, Italy, Liberia, the Netherlands, Spain, Switzerland and the United Kingdom.
Author: James R. Repetti Publisher: 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.
Author: Robert Meldman Publisher: 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: Paul McDaniel Publisher: Springer ISBN: Category : Business & Economics Languages : en Pages : 240
Book Description
Tax practitioners outside the United States whose clients have activities in the country generally rely on their U.S. tax advisors for technical advice on the U.S. tax aspects of their clients' transactions. In order to position themselves to evaluate the advice received and to relate it to their own tax systems, however, foreign tax advisors must place the material they receive from their U.S. counterparts within the overall structure of the U.S. international tax system. Introduction to United States International Taxation provides the structural framework within which a U.S. tax problem can be placed. Now in its fourth edition, this reliable resource presents the basic principles and rules of the U.S. international tax system in a concise, manageable form. Without becoming mired in technical detail, The book provides an overview of the principles adopted by the United States in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the United States or abroad. The inclusion of or reference to many key primary source documents enhances the usefulness of Introduction to United States International Taxation. These include: Internal Revenue Code provisions under discussion the more important Treasury Regulations issued interpreting the statutory rules significant administrative announcements of the Internal Revenue Service (Revenue Rulings and Revenue Procedures) illustrative principal cases
Author: John Abrahamson Publisher: Kluwer Law International B.V. ISBN: 9041191208 Category : Law Languages : en Pages : 546
Book Description
Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.
Author: Peter A. Glicklich
Author: Peter A. Glicklich
Author: Guglielmo Maisto
Author: James R. Repetti
Author: Robert Meldman
Author: Philip F. Postlewaite
Author: Paul McDaniel
Author: John Abrahamson
Author: United States. Congress. Joint Committee on Taxation
Author: 
Author: