International Income Taxation

Author : Robert J. Peroni,Charles H. Gustafson,Richard Crawford Pugh
Publisher : CCH
Page : 2356 pages
File Size : 51,5 Mb
Release : 2008
Category : Corporations, Foreign
ISBN : 0808018752

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International Income Taxation by Robert J. Peroni,Charles H. Gustafson,Richard Crawford Pugh Pdf

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 : Anonim
Publisher : Unknown
Page : 12 pages
File Size : 55,7 Mb
Release : 1988
Category : Income tax
ISBN : MINN:31951D013914451

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Self-employment Tax by Anonim Pdf

Author : Vern Krishna
Publisher : Unknown
Page : 680 pages
File Size : 49,9 Mb
Release : 2019
Category : Corporations, Foreign
ISBN : 0433502509

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Income Tax (international) by Vern Krishna Pdf

Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 40,8 Mb
Release : 2021-07-07
Category : Law
ISBN : 9789403523903

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Introduction to United States International Taxation by James R. Repetti,Diane M. Ring,,Stephen Shay Pdf

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 : Philippe Malherbe
Publisher : Bruylant
Page : 145 pages
File Size : 50,8 Mb
Release : 2015-05-26
Category : Law
ISBN : 9782802750543

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Elements of International Income Taxation by Philippe Malherbe Pdf

Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.

Author : Timo Viherkenttä
Publisher : Unknown
Page : 292 pages
File Size : 47,5 Mb
Release : 1991
Category : Foreign tax credit
ISBN : STANFORD:36105061182684

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Tax Incentives in Developing Countries and International Taxation by Timo Viherkenttä Pdf

Examines the complex coordination of tax incentives for foreign investors and international taxation. The analysis locates the factors which tend to frustrate such incentives through increased taxation in the investor's home country. The various tax planning techniques for avoiding the loss of incentive benefits are also dealt with.

Author : Robert Couzin
Publisher : IBFD
Page : 295 pages
File Size : 40,5 Mb
Release : 2002
Category : Conflict of laws
ISBN : 9789076078489

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Corporate Residence and International Taxation by Robert Couzin Pdf

Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.

Author : John Goodwin Herndon
Publisher : Unknown
Page : 322 pages
File Size : 46,7 Mb
Release : 1932
Category : Double taxation
ISBN : MINN:31951001559169R

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Relief from International Income Taxation by John Goodwin Herndon Pdf

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 : Gary Clyde Hufbauer
Publisher : Peterson Institute
Page : 340 pages
File Size : 53,7 Mb
Release : 2007
Category : Corporations, Foreign
ISBN : 9780881325737

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US Taxation of Foreign Income by Gary Clyde Hufbauer Pdf

Author : Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 50,9 Mb
Release : 2019-01-14
Category : Law
ISBN : 9789403501727

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International Tax Primer by Brian J. Arnold Pdf

Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.

Author : Jagdish N. Bhagwati,John Douglas Wilson
Publisher : MIT Press
Page : 256 pages
File Size : 50,7 Mb
Release : 1989
Category : Business & Economics
ISBN : 0262022923

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Income Taxation and International Mobility by Jagdish N. Bhagwati,John Douglas Wilson Pdf

Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to "tax the brain drain."Today millions of people work in countries where they are not citizens. Income Taxation and International Mobility addresses the novel theoretical and practical problems that this growing phenomenon of international personal mobility creates for the design of a country's tax system and takes up questions that have grown largely out of the extensive debate over Jagdish Bhagwati's proposal in the early 1970s to tax the brain drain. The contributors, who include many of the leading theorists of international economics and public finance, look at how the difficult question of how horizontal equity is to be defined - between nationals at home and abroad or between nationals abroad and foreign citizens abroad - and tackle such questions as Should a country exercise income tax jurisdiction over its citizens abroad? If so, in what way? Is it practical to do so? The issues that these questions raise are complex, lying on the interface of politics, sociology, and economics. Income Taxation and International Mobility breaks significant new ground by analyzing these questions and building on the modern theory of optimal income taxation to examine the consequences of the possibility of outmigration on the appropriate exercise and design of income tax jurisdiction on those who live outside their native country. Theoretical analyses are presented in six chapters by the editors and by James Mirrlees, William Baumol, and Koichi Hamada. The well known tax law expert, Richard Pomp, examines the Philippines experience in taxing citizens abroad. The editors provide a substantial introduction that synthesizes the book's major analytical approaches and conclusions, and Richard Musgrave provides an insightful view of the issues in his Foreword.

Author : Joseph Isenbergh
Publisher : Thomson West
Page : 322 pages
File Size : 45,5 Mb
Release : 2005
Category : Business & Economics
ISBN : STANFORD:36105063840743

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International Taxation by Joseph Isenbergh Pdf

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 : Alberto Giovannini,R. Glenn Hubbard,Joel Slemrod
Publisher : University of Chicago Press
Page : 336 pages
File Size : 41,8 Mb
Release : 2007-12-01
Category : Business & Economics
ISBN : 9780226297033

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Studies in International Taxation by Alberto Giovannini,R. Glenn Hubbard,Joel Slemrod Pdf

As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies. The contributors to this volume are Rosanne Altshuler, Alan J. Auerbach, Neil Bruce, Timothy Goodspeed, Roger H. Gordon, Harry Grubert, Bronwyn H. Hall, David Harris, Kevin Hassett, James R. Hines Jr., Roy D. Hogg, Joosung Jun, Jeffrey K. Mackie-Mason, Jack M. Mintz, Randall Morck, John Mutti, T. Scott Newlon, James M. Poterba, Joel Slemrod, Deborah Swenson, G. Peter Wilson, and Bernard Yeung.

Author : Joseph Isenbergh
Publisher : Aspen Publishers
Page : 870 pages
File Size : 42,7 Mb
Release : 1990
Category : Business & Economics
ISBN : STANFORD:36105060968158

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International Taxation by Joseph Isenbergh Pdf

Comprehensive guide on the tax consequences of inbound transactions.

Author : Boris I. Bittker
Publisher : Unknown
Page : 102 pages
File Size : 51,8 Mb
Release : 1991
Category : Aliens
ISBN : IND:30000086970948

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Fundamentals of International Taxation by Boris I. Bittker Pdf