International Taxation U S Taxation Of Foreign Persons And Foreign Income

Author : Joseph Isenbergh,Bret Wells
Publisher : Unknown
Page : 0 pages
File Size : 49,9 Mb
Release : 2023-12-28
Category : Electronic
ISBN : 080805886X

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International Taxation: Us Taxation of Foreign Persons & Foreign Income 2024 by Joseph Isenbergh,Bret Wells Pdf

International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to: -Structure international corporate transactions for maximum benefit. -Minimize liability under applicable laws and treaties. -Practice effectively and compliantly within the complex web of legal authority. The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts: Part I Elements of International Taxation Part II U.S. Taxation of Nonresident Aliens and Foreign Corporations Part III U.S. Taxation of Foreign Income Part IV Foreign Currency Questions Part V International Corporate Reorganizations Part VI Income Tax Treaties Part VII Withholding in International Taxation Part VIII International Transfer Taxation Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.

Author : Joseph Isenbergh
Publisher : CCH
Page : 806 pages
File Size : 48,9 Mb
Release : 2006
Category : Aliens
ISBN : 0808016164

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International Taxation by Joseph Isenbergh Pdf

Author : J. Isenbergh
Publisher : Unknown
Page : 0 pages
File Size : 42,8 Mb
Release : 2000
Category : Electronic
ISBN : OCLC:950085417

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International Taxation : U.S. Taxation of Foreign Persons and Foreign Income by J. Isenbergh Pdf

Treatise on international aspects of US individual and corporate income taxation. Explains the basic principles of US international taxation (residence, source etc) and contains detailed explanations of all aspects of outbound and inbound transactions. Part 1: Basic elements of international taxation; Part 2: Inbound U.S. taxation ; Part 3: Outbound U.S. taxation; Part 4: Income tax treaties.

Author : Gary Clyde Hufbauer
Publisher : Peterson Institute
Page : 340 pages
File Size : 42,9 Mb
Release : 2007
Category : Corporations, Foreign
ISBN : 9780881325737

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US Taxation of Foreign Income by Gary Clyde Hufbauer Pdf

Author : Joseph Isenbergh
Publisher : Unknown
Page : 790 pages
File Size : 46,9 Mb
Release : 2009-11
Category : Electronic
ISBN : 0808022539

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International Taxation by Joseph Isenbergh Pdf

Author : Joseph Isenbergh
Publisher : Thomson West
Page : 322 pages
File Size : 51,7 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 : Joseph Isenbergh
Publisher : Aspen Publishers
Page : 128 pages
File Size : 43,7 Mb
Release : 1998-10-01
Category : Electronic
ISBN : 0735517037

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International Taxation by Joseph Isenbergh Pdf

Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 51,5 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 : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 42,8 Mb
Release : 1997
Category : Business & Economics
ISBN : STANFORD:36105062261552

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A Practical Guide to U. S. Taxation of International Transactions by Robert Meldman,Michael S. Schadewald Pdf

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.

Author : Joseph Isenbergh
Publisher : Aspen Publishers
Page : 872 pages
File Size : 48,6 Mb
Release : 1990
Category : Business & Economics
ISBN : UCAL:B4279769

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International Taxation by Joseph Isenbergh Pdf

Comprehensive guide on the tax consequences of inbound transactions.

Author : Joseph Isenbergh,Bret Wells
Publisher : Unknown
Page : 128 pages
File Size : 40,7 Mb
Release : 2021-02-15
Category : Electronic
ISBN : 0808055542

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International Taxation: U.S. Taxation of Foreign Persons and Foreign Income 2021 by Joseph Isenbergh,Bret Wells Pdf

International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners.

Author : Joseph Isenbergh
Publisher : Unknown
Page : 128 pages
File Size : 52,6 Mb
Release : 2015-12-24
Category : Electronic
ISBN : 0808043447

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International Taxation by Joseph Isenbergh Pdf

International Taxation is a comprehensive four volume treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to:-Structure international corporate transactions for maximum benefit.-Minimize liability under applicable laws and treaties.-Practice effectively and compliantly within the complex web of legal authority.The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts:Part I Elements of International Taxation Part II U.S. Taxation of Nonresident Aliens and Foreign CorporationsPart III U.S. Taxation of Foreign IncomePart IV Foreign Currency QuestionsPart V International Corporate ReorganizationsPart VI Income Tax TreatiesPart VII Withholding in International Taxation Part VIII International Transfer Taxation Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.

Author : Joseph Isenbergh J.D.
Publisher : Unknown
Page : 128 pages
File Size : 55,7 Mb
Release : 2017-12-15
Category : Electronic
ISBN : 0808048120

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International Taxation by Joseph Isenbergh J.D. Pdf

Author : Joseph Isenbergh,Bret Wells
Publisher : Unknown
Page : 2200 pages
File Size : 52,7 Mb
Release : 2022-12-28
Category : Electronic
ISBN : 0808057693

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International Taxation: Us Taxation of Foreign Persons&foreign Income 2023 by Joseph Isenbergh,Bret Wells Pdf

International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to: -Structure international corporate transactions for maximum benefit. -Minimize liability under applicable laws and treaties. -Practice effectively and compliantly within the complex web of legal authority. The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts: Part I Elements of International Taxation Part II U.S. Taxation of Nonresident Aliens and Foreign Corporations Part III U.S. Taxation of Foreign Income Part IV Foreign Currency Questions Part V International Corporate Reorganizations Part VI Income Tax Treaties Part VII Withholding in International Taxation Part VIII International Transfer Taxation Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.

Author : Joseph Isenbergh
Publisher : Unknown
Page : 128 pages
File Size : 51,6 Mb
Release : 2015-12-21
Category : Electronic
ISBN : 0808045849

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International Taxation by Joseph Isenbergh Pdf

International Taxation is a comprehensive four volume treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to:-Structure international corporate transactions for maximum benefit.-Minimize liability under applicable laws and treaties.-Practice effectively and compliantly within the complex web of legal authority