Taxation Of Foreign Income
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US Taxation of Foreign Income
Author | : Gary Clyde Hufbauer |
Publisher | : Peterson Institute |
Total Pages | : 340 |
Release | : 2007 |
Genre | : Corporations, Foreign |
ISBN | : 0881325732 |
International Taxation
Author | : Joseph Isenbergh |
Publisher | : CCH |
Total Pages | : 966 |
Release | : 2006 |
Genre | : Aliens |
ISBN | : 9780808016168 |
Statistics of Income
Author | : |
Publisher | : |
Total Pages | : 434 |
Release | : 1976 |
Genre | : Controlled foreign corporations |
ISBN | : |
International Taxation
Author | : Joseph Isenbergh |
Publisher | : Aspen Publishers |
Total Pages | : 872 |
Release | : 1990 |
Genre | : Business & Economics |
ISBN | : |
Comprehensive guide on the tax consequences of inbound transactions.
Practical Problems in Taxation of Foreign Operations
Author | : Institute on U.S. Taxation of Foreign Income |
Publisher | : |
Total Pages | : 230 |
Release | : 1965 |
Genre | : Income tax |
ISBN | : |
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.
A Practical Guide to U.S. Taxation of International Transactions
Author | : Robert E. Meldman |
Publisher | : Springer |
Total Pages | : 516 |
Release | : 2000-06-22 |
Genre | : Business & Economics |
ISBN | : |
This book discusses basis principles (tax jurisdiction, source of income rules), U.S. taxation of foreign income (foreign tax credit, transfer pricing, anti-avoidance provisions governing foreign corporations, foreign sales corporations, foreign currency translation and transactions, tax treaties, planning of foreign operations) and U.S. taxation of foreign persons (foreign persons investing in the U.S. and foreign persons doing business in the U.S.).
International Taxation
Author | : Joseph Isenbergh |
Publisher | : Thomson West |
Total Pages | : 328 |
Release | : 2005 |
Genre | : Business & Economics |
ISBN | : |
International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index