United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
Total Pages: 40
Release: 2018-11-12
Genre:
ISBN: 9781729735749

United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that provide rules regarding the treatment as United States property of property held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income (FPHCI), as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions. This document finalizes proposed regulations, and withdraws temporary regulations, published on September 2, 2015. It also finalizes proposed regulations, and withdraws temporary regulations, published on June 14, 1988. The final regulations affect United States shareholders of CFCs. This book contains: - The complete text of the United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships - Rents and Royalties Derived in Active Conduct (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

United States Code

United States Code
Author: United States
Publisher:
Total Pages: 1506
Release: 2013
Genre: Law
ISBN:

"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

U.S. Tax Treaties

U.S. Tax Treaties
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 28
Release: 1990
Genre: Double taxation
ISBN:

Taxation of International Transactions

Taxation of International Transactions
Author: Charles H. Gustafson
Publisher: West Academic Publishing
Total Pages: 0
Release: 2011
Genre: Casebooks
ISBN: 9780314911711

Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.