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Author : Michael J. Graetz
Publisher : Unknown
Page : 0 pages
File Size : 55,6 Mb
Release : 2003
Category : Aliens
ISBN : 1587785153
An overview of international income tax law, the institutions that shape that law and the underlying policy debates, with numerous extracts from the scholarly literature on the subject.
Author : Jon E. Bischel,Robert Feinschreiber
Publisher : Unknown
Page : 586 pages
File Size : 48,6 Mb
Release : 1985
Category : Conflict of laws
ISBN : UCAL:B4316289
Comprehensive overview of the Unisted States tax laws that affect international business, including international trade, investment, and finance. The various chapters consider jurisdiction to tax, source of income, deductions, organization of foreign operations, forming a foreign corporation, foreign tax credit, controlled foreign corporations, restructuring the foreign enterprise, characterization of gains and losses, export structures (DISC and FSC), possessions corporations, Americans overseas, general rules for foreign activitities in the USA, foreign individuals, foreign corporations, foreign taxes and related considerations, intercompany transactions, tax treaties, general tax avoidance provisions, international tax compliance, tax consequences of boycott involvement, state taxation of multinational operations, intellectual property, real estate, international leasing, exporting, importing, manufacturing, and use of international funds,
Author : Boris I. Bittker
Publisher : Unknown
Page : 102 pages
File Size : 50,8 Mb
Release : 1991
Category : Aliens
ISBN : IND:30000086970948
Author : Robert J. Peroni,Charles H. Gustafson,Richard Crawford Pugh
Publisher : CCH
Page : 2356 pages
File Size : 46,6 Mb
Release : 2008
Category : Corporations, Foreign
ISBN : 0808018752
Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.
Author : David Duff,Benjamin Alarie,Geoffrey Loomer,Lisa Philipps
Publisher : Unknown
Page : 1420 pages
File Size : 47,5 Mb
Release : 2018
Category : Income tax
ISBN : 043349560X
Author : Vern Krishna
Publisher : Carswell Legal Publications
Page : 1272 pages
File Size : 50,5 Mb
Release : 1986-01-01
Category : Law
ISBN : 0459390805
Author : John Goodwin Herndon
Publisher : Unknown
Page : 322 pages
File Size : 51,7 Mb
Release : 1932
Category : Double taxation
ISBN : MINN:31951001559169R
History of the movement to prevent the double taxation of income internationally. Attempt to ascertain what specific recommendations could be made to the governments of the world which would have a reasonable change of being adopted and which, if adopted, would prevent international double taxation.
Author : Hugh J. Ault,Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 594 pages
File Size : 46,9 Mb
Release : 2010-01-01
Category : Business & Economics
ISBN : 9789041132048
The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.
Author : Reuven Shlomo Avi-Yonah,Nicola Sartori,Omri Marian
Publisher : Oxford University Press, USA
Page : 202 pages
File Size : 52,5 Mb
Release : 2011
Category : Law
ISBN : 9780195321364
In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.
Author : Lawrence Lokken
Publisher : Unknown
Page : 88 pages
File Size : 47,9 Mb
Release : 2011
Category : Aliens
ISBN : 0791379388
Author : Robert J. Peroni,Charles H. Gustafson,Richard Crawford Pugh
Publisher : CCH Incorporated
Page : 0 pages
File Size : 46,6 Mb
Release : 2016-07-16
Category : Corporations, Foreign
ISBN : 0808044184
Compiled by a team of distinguished law professors, the 2014-2015 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4" x 10" format with new larger type fonts for enhanced readability
Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 50,6 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 : John Castro
Publisher : Unknown
Page : 128 pages
File Size : 47,5 Mb
Release : 2018-09-07
Category : Electronic
ISBN : 1732359903
Author : American Law Institute
Publisher : Unknown
Page : 546 pages
File Size : 46,5 Mb
Release : 1987
Category : Aliens
ISBN : STANFORD:36105061894619
Proposals on United States taxation of foreign persons and of the foreign income of United States persons.
Author : Joseph Isenburgh
Publisher : Company Law & Business
Page : 1474 pages
File Size : 53,9 Mb
Release : 1989-10-01
Category : Electronic
ISBN : 0316432873
This new treatise provides the practitioner with detailed guidance on United States tax law as it affects foreign taxpayers and foreign income. The work addresses the full range of U.S. tax question arising under the IRC and tax treaties and their impact on invstment and business transactions accross national boundaries.