International Taxation

International Taxation
Author: Philip F. Postlewaite
Publisher:
Total Pages: 0
Release: 2010
Genre: Corporations, Foreign
ISBN: 9781594607974

This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.

Tax Guide for U.S. Citizens and Resident Aliens Abroad - Publication 54 ( For Use in Preparing 2020 Returns)

Tax Guide for U.S. Citizens and Resident Aliens Abroad - Publication 54 ( For Use in Preparing 2020 Returns)
Author: Internal Revenue Service
Publisher:
Total Pages: 38
Release: 2021-03-04
Genre:
ISBN: 9781678085124

This publication discusses special tax rules for U.S. citizens and resident aliens who work abroad or who have income earned in foreign countries. If you are a U.S. citizen or resident alien, your worldwide income is generally subject to U.S. income tax, regardless of where you are living. Also, you are subject to the same income tax filing requirements that apply to U.S. citizens or resident aliens living in the United States. Expatriation tax provisions apply to U.S. citizens who have renounced their citizenship and long-term residents who have ended their residency. These provisions are discussed in chapter 4 of Pub. 519, U.S. Tax Guide for Aliens. Resident alien. A resident alien is an individual who is not a citizen or national of the United States and who meets either the green card test or the substantial presence test for the calendar year.

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.