Practical Guide To United States Taxation Of International Transactions

Author : Michael S. Schadewald,Robert J. Misey
Publisher : Unknown
Page : 0 pages
File Size : 41,5 Mb
Release : 2015
Category : Business & Economics
ISBN : 0808040847

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

Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

Author : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 45,9 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 : Michael Schadewald,Misey Jr. Robert
Publisher : Unknown
Page : 920 pages
File Size : 54,6 Mb
Release : 2022-08-14
Category : Electronic
ISBN : 0808058444

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Practical Guide to U.S. Taxation of International Transactions (13th) by Michael Schadewald,Misey Jr. Robert Pdf

Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

Author : Robert E. Meldman,Michael Schadewald
Publisher : Springer
Page : 516 pages
File Size : 49,8 Mb
Release : 2000-06-22
Category : Business & Economics
ISBN : STANFORD:36105060329153

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

This book discusses basis principles (tax jurisdiction, source of income rules), U.S. taxation of foreign income (foreign tax credit, transfer pricing, anti-avoidance provisions governing foreign corporations, foreign sales corporations, foreign currency translation and transactions, tax treaties, planning of foreign operations) and U.S. taxation of foreign persons (foreign persons investing in the U.S. and foreign persons doing business in the U.S.).

Author : Robert J. Misey,Michael S. Schadewald
Publisher : Unknown
Page : 18 pages
File Size : 45,7 Mb
Release : 2007-09-01
Category : Aliens
ISBN : 0808017888

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

Author : Michael S. Schadewald,Robert J. Misey
Publisher : Unknown
Page : 28 pages
File Size : 41,7 Mb
Release : 2006
Category : Aliens
ISBN : 080801479X

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

Author : Robert T. Cole
Publisher : Aspen Publishers
Page : 1302 pages
File Size : 44,5 Mb
Release : 1999
Category : Business & Economics
ISBN : PSU:000043671397

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Practical Guide to U.S. Transfer Pricing by Robert T. Cole Pdf

Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Author : Michael S. Schadewald,Robert J. Misey, Jr.
Publisher : Unknown
Page : 104 pages
File Size : 45,9 Mb
Release : 2006-02-01
Category : Electronic
ISBN : 0808014781

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Practical Guide to US Taxation of International Transactions by Michael S. Schadewald,Robert J. Misey, Jr. Pdf

This is a free Instructor's Guide for teachers that adopt the textbook.

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 44,7 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827

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U.S. Tax Guide for Aliens by Anonim Pdf

Author : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 50,6 Mb
Release : 2019-01-03
Category : Law
ISBN : 9789041190215

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Fundamentals of Transfer Pricing by Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck Pdf

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.

Author : Paul R. McDaniel,James R. Repetti,Diane M. Ring
Publisher : Unknown
Page : 0 pages
File Size : 54,5 Mb
Release : 2014
Category : Aliens
ISBN : 9041136568

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

This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. 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.

Author : Michael D. Rashkin
Publisher : CCH
Page : 764 pages
File Size : 41,5 Mb
Release : 2007
Category : Business & Economics
ISBN : 0808014323

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Practical Guide to Research and Development Tax Incentives by Michael D. Rashkin Pdf

CCH's Practical Guide to Research and Development Tax Incentives--Federal, State, and Foreign by Michael Rashkin, J.D., LL.M., provides something that has been missing in professional tax literature--authoritative, comprehensive coverage of this complex and evolving topic. This newly expanded resource is practical, easy to follow, easy to understand, and is particularly effective at clarifying and demystifying this complex subject. It provides well-written, detailed guidance on claiming the federal credit for increasing research activities and the deduction for R & D expenditures. In doing so, it explains the elements of qualified research, exclusions, computational rules, and basic research payment credits. Historically, the IRS has been vigilant in denying R & D credits. This resource explains how to satisfy the IRS's requirements, document the credit, and defend against IRS challenges. It also examines research incentives offered by individual states and describes the R & D incentives available in the major economies of the world, offering helpful charts that show the key differences among the various countries.

Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 48,9 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 : Philip R. West,J. Walker Johnson,Michael Durst,Amanda Varma
Publisher : Unknown
Page : 0 pages
File Size : 44,8 Mb
Release : 2015
Category : Business enterprises
ISBN : 1402425139

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International Tax Controversies by Philip R. West,J. Walker Johnson,Michael Durst,Amanda Varma Pdf

With the U.S. Justice Department taking an ever-closer look at cross-border transactions and their tax implications, the new International Tax Controversies: A Practical Guide provides a detailed roadmap to how to prepare for a tax audit that involves an international component. Creating and retaining the proper transaction-related documentation, and understanding what additional documentation might be needed for an international examination, is vital to a successful audit. International Tax Controversies describes the process of how an international audit proceeds, including providing information on: How the IRS audit team is chosenWhat the limits are of the scope of the examinationThe type of examination that will be conducted and the kinds of documents that will need to be provided by the taxpayer and third partiesThe kinds of enforcement procedures that may be broughtIn international tax situations, there are often conflicting positions taken by the U.S. Internal Review Service and a non-U.S. tax authority. Tax treaties containing mutual agreement procedures (MAPs) are often invoked to protect the taxpayer from paying double taxes. International Tax Controversies describes the process by which MAPs may be invoked and a binding resolution created. As most disagreements between international taxing entities involve transfer pricing issues, there is generally an opportunity to obtain an advance pricing agreement (APA) to protect the taxpayer. International Tax Controversies analyzes the APA process, providing a detailed guide on facilitating the process for your client. It also describes the many tax information exchange treaties and agreements that the U.S. has entered into, and the impact they have had on the U.S. taxpayer.

Author : Angela W. Yu
Publisher : Kluwer Law International B.V.
Page : 384 pages
File Size : 54,8 Mb
Release : 2017-10-24
Category : Law
ISBN : 9789041184658

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The US Foreign Investment in Real Property Tax Act by Angela W. Yu Pdf

U.S. real estate is enormously attractive to many foreign investors, who are thus ushered into the ambit of the complex U.S. Foreign Investment in Real Property Tax Act (FIRPTA). A full understanding of the associated tax implications on the part of these investors and their advisors is essential if they are to implement the correct structure to maximize their returns, avoid unnecessary withholding, and comply with applicable requirements. This book, the first practical guide to FIRPTA, clearly articulates the operation and transactional implications of FIRPTA and its interaction with various other regimes, sets forth real life situations, and points out potential traps, all in a readily graspable format. Among the tax issues and consequences that directly or indirectly affect foreign investors in U.S. real property interests, the author highlights the following and more: • the real estate investment trust (REIT); • withholding taxes that are jointly and severally liable for buyers and sellers; • treatment of rental, interest, and dividend income; • effect of the branch profits tax; • tax treaty benefits; • exemptions to FIRPTA; • special rules applicable to foreign governmental investors; • tax reporting standards and potential penalties for noncompliance; and • state and local tax issues relating to U.S. real estate investments. Providing a straightforward and accessible guide for navigating the tax issues that confront foreign investors in U.S. real estate, this resource will prove invaluable in identifying and formulating the correct strategies for investors and their advisors with respect to investments in the U.S. real estate market. It is sure to benefit all interested parties for years to come. Angela W. Yu, a tax partner of KPMG’s New York office, has extensive experience providing integrated tax advice to clients on cross-border transactions. She is a frequent speaker on U.S. tax issues, and has addressed many professional organizations.