U.S. Tax Treaties

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

Introduction to United States International Taxation

Introduction to United States International Taxation
Author: James R. Repetti
Publisher: Kluwer Law International B.V.
Total Pages: 458
Release: 2021-07-07
Genre: Law
ISBN: 9403523905

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.

Federal Income Tax Project

Federal Income Tax Project
Author: American Law Institute
Publisher:
Total Pages: 546
Release: 1987
Genre: Law
ISBN:

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

A Practical Guide to U. S. Taxation of International Transactions
Author: Robert Meldman
Publisher: Springer
Total Pages: 408
Release: 1997
Genre: Business & Economics
ISBN:

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.