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Author : Daniel N. Shaviro
Publisher : Oxford University Press
Page : 242 pages
File Size : 42,7 Mb
Release : 2014-04
Category : Law
ISBN : 9780199359752
Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Author : Daniel N. Shaviro
Publisher : Oxford University Press
Page : 256 pages
File Size : 50,6 Mb
Release : 2014-01-08
Category : Law
ISBN : 9780199359769
International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
Author : Boris I. Bittker
Publisher : Unknown
Page : 102 pages
File Size : 54,9 Mb
Release : 1991
Category : Aliens
ISBN : IND:30000086970948
Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 52,9 Mb
Release : 2021-07-07
Category : Law
ISBN : 9789403523903
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 : Jane G. Gravelle
Publisher : DIANE Publishing
Page : 24 pages
File Size : 49,8 Mb
Release : 2011-04
Category : Reference
ISBN : 9781437980899
Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? Contents of this report: The Current System and Possible Revisions; Neutrality, Efficiency, and Competitiveness; Assessing the Existing Tax System; Territorial Taxation: The Dividend Exemption Proposal; A Residence-Based System in Practice; President Obama's Proposals to Restrict Deferral and Cross-Crediting; Tax Havens: Issues and Policy Options; General Reforms of the Corporate Tax and Implications for International Tax Treatment. Charts and tables. This is a print on demand edition of an important, hard-to-find publication.
Author : Paul R. McDaniel,Hugh J. Ault
Publisher : Springer
Page : 232 pages
File Size : 46,6 Mb
Release : 1981-06-17
Category : Business & Economics
ISBN : STANFORD:36105043742290
This book presents the basic priciples and rules of the United States international tax system in a relatively brief form. The purpose is to provide an overview of 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.
Author : David Brumbaugh
Publisher : Unknown
Page : 0 pages
File Size : 49,5 Mb
Release : 2007
Category : Investments, Foreign
ISBN : OCLC:385388253
A striking feature of the modern U.S. economy is its growing openness--its increased integration with the rest of the world. The attention of tax policymakers has recently been focused on the growing participation of U.S. firms in the international economy and the increased pressure that engagement places on the U.S. system for taxing overseas business. Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? The current U.S. system for taxing international business is a hybrid. In part the system is based on a residence principle, applying U.S. taxes on a worldwide basis to U.S. firms while granting foreign tax credits to alleviate double taxation. The system, however, also permits U.S. firms to defer foreign-source income indefinitely -a feature that approaches a territorial tax jurisdiction. In keeping with its mixed structure, the system produces a patchwork of economic effects that depend on the location of foreign investment and the circumstances of the firm. Broadly, the system poses a tax incentive to invest in countries with low-tax rates of their own and a disincentive to invest in high-tax countries. In theory, U.S. investment should be skewed towards low-tax countries and away from high-tax locations. Evaluations of the current tax system vary, and so do prescriptions for reform. According to traditional economic analysis, world economic welfare is maximized by a system that applies the same tax burden to prospective (marginal) foreign and domestic investment so that taxes do not distort investment decisions. Such a system possesses "capital export neutrality," and could be accomplished by worldwide taxation applied to all foreign operations along with an unlimited foreign tax credit. In contrast, a system that maximizes national welfare-a system possessing "national neutrality"--Would impose a higher tax burden on foreign investment, thus permitting an overall disincentive for foreign investment. Such a system would impose worldwide taxation, but would permit only a deduction, and not a credit, for foreign taxes. A tax system based on territorial taxation would exempt overseas business investment from U.S. tax. In recent years, several proponents of territorial taxation have argued that changes in the world economy have rendered traditional prescriptions for international taxation obsolete, and instead prescribe territorial taxation as a means of maximizing both world and national economic welfare. For such a system to be neutral, however, capital would have to be completely immobile across locations. A case might be made that such a system is superior to the current hybrid system, but it is not clear that it is superior to other reforms, including not only a movement toward worldwide taxation by ending deferral, but also restricting deductions for costs associated with deferred income or restricting deferral and foreign tax credits for tax havens. This report will not be updated
Author : Cym H. Lowell
Publisher : Unknown
Page : 1334 pages
File Size : 45,7 Mb
Release : 1997
Category : Business & Economics
ISBN : MINN:31951D01839594H
Author : Adnan Islam
Publisher : John Wiley & Sons
Page : 304 pages
File Size : 40,8 Mb
Release : 2020-09-01
Category : Business & Economics
ISBN : 9781119756491
Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction. Information is provided for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017, this guide covers international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the United States. Key topics include: Export income Receipts in foreign currency Allocation and apportionment of deductions U.S. foreign tax credit fundamentals and special rules Initiation of foreign operations Foreign branches and affiliated companies Sale of use of tangible property Foreign business operations in the United States Foreign business sales of tangible property in the United States Foreign business provision of services in the United States Exploitation of business assets outside of the United States Use of foreign tangible/intangible property in the United States U.S. withholding taxes on foreign businesses FDII GILTI
Author : Paul McDaniel,Hugh J. Ault
Publisher : Springer
Page : 240 pages
File Size : 55,8 Mb
Release : 1998-02-25
Category : Business & Economics
ISBN : STANFORD:36105060360745
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 : Joseph Isenbergh
Publisher : Thomson West
Page : 322 pages
File Size : 47,5 Mb
Release : 2005
Category : Business & Economics
ISBN : STANFORD:36105063840743
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
Author : Jane Gravelle
Publisher : Unknown
Page : 22 pages
File Size : 47,7 Mb
Release : 2017
Category : Investments, Foreign
ISBN : OCLC:1097457958
Author : Joseph Isenbergh
Publisher : Aspen Publishers
Page : 870 pages
File Size : 47,6 Mb
Release : 1990
Category : Aliens
ISBN : STANFORD:36105060968158
Comprehensive guide on the tax consequences of inbound transactions.
Author : Richard L. Doernberg
Publisher : West Academic Publishing
Page : 0 pages
File Size : 46,9 Mb
Release : 2007
Category : Aliens
ISBN : 0314163107
This book provides an introduction to the US law of international taxation. After an introduction to the fundamentals of US international taxation and the source rules, this book addresses investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profits tax and the provisions affecting foreign investment in US real estate. Also included are chapters on US income tax treaties and filing withholding and reporting requirements. The last part of the book is directed at investment and business activities of US citizens, residents and domestic corporations outside the US. The centerpiece is a consideration of the US foreign tax credit. Intercompany pricing, controlled foreign corporations, the treatment of foreign currency, and international tax-free transactions are discussed, as well as tax arbitrage.
Author : Jon E. Bischel,Robert Feinschreiber
Publisher : Unknown
Page : 482 pages
File Size : 54,9 Mb
Release : 1977
Category : Conflict of laws
ISBN : UOM:35128000299014
Discussion of the United States tax laws that effect international business, including international trade, investment and finance as of Tax Reform Act of 1976.