Taxation Of International Business Transactions

Author : Felix I. Lessambo
Publisher : iUniverse
Page : 0 pages
File Size : 43,6 Mb
Release : 2009
Category : Business & Economics
ISBN : 9780595532520

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Taxation of International Business Transactions by Felix I. Lessambo Pdf

"With the increase in global trade now and in the future and the growth of multinational companies, an understanding of international tax law is imperative. In Taxation of International Business Transactions, author Dr. Felix Lessambo provides an overview of the sometimes challenging international tax law. Taxation of International Business Transactions provides sound understanding of foreign tax regimes and more. It is geared for those who want to mitigate, increase, and avoid tax audits in the areas of thin-capitalization, employee-secondment, transfer pricing, and limitations-on-benefits (LOB). Lessambo has tracked the ongoing issues of the most relevant aspects of international taxations and delivers suggestions in this edition. Lessambo, an international tax scholar and practitioner recognized for his keen analyses, provides firsthand expertise to help multinationals and international business managers to pursue business initiatives without the fear of unintended tax consequences. Taxation of International Business Transactions is an indispensable guide for tax and financial directors and those dealing with tax at a worldwide level."--Publisher's website.

Author : William John Gibbons
Publisher : Unknown
Page : 200 pages
File Size : 42,6 Mb
Release : 1957
Category : Corporations, American
ISBN : UOM:49015000414483

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Tax Factors in Basing International Business Abroad by William John Gibbons Pdf

Author : Manuel C. Solbach
Publisher : Springer Nature
Page : 144 pages
File Size : 51,7 Mb
Release : 2023-11-12
Category : Business & Economics
ISBN : 9783031392405

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International Business Transactions and Taxation by Manuel C. Solbach Pdf

Recent developments in the taxation of international enterprises are driven by the Organisation for Economic Co-operation and Development (OECD) of the Base Erosion and Profit Shifting (BEPS) initiative and have contributed to increase attention in practice, especially of large enterprises, resulting in different routes of action. This book provides a comprehensive overview of international business transactions at the customer interface with a focus on the specific role and tasks of the functions within a company. Three basic transactional models are introduced and analyzed, particularly to what extent they induce an international tax risk to the enterprise, in order to explore meaningful choices for action. The book inspires experienced practitioners as well as young professionals with or without formal business education to think beyond the context of their own experience and to define, implement and monitor tax-compliant transactional processes in their respective business. Individuals in companies are sensitized for compliance to these business processes resulting in a reduction of a hidden or frequently neglected, but significant tax risk. This book helps executives and managers create a shared understanding on international business transactions and facilitate detailed cross-functional discussions.

Author : Michael S. Schadewald,Robert J. Misey
Publisher : Unknown
Page : 0 pages
File Size : 55,8 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 : Sol Picciotto
Publisher : Praeger
Page : 424 pages
File Size : 53,6 Mb
Release : 1992-03-02
Category : Business & Economics
ISBN : UCSD:31822015164999

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International Business Taxation by Sol Picciotto Pdf

This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

Author : William P. Streng,Jeswald W. Salacuse
Publisher : International Institute of Technology, Incorporated
Page : 128 pages
File Size : 53,6 Mb
Release : 2011
Category : Export sales contracts
ISBN : 0820513881

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International Business Planning by William P. Streng,Jeswald W. Salacuse Pdf

A guide to the common legal, tax and financial planning of the international business transaction, and for the management of existing undertakings. Part one analyzes the framework for international business: the general business climate, monetary, trade, financial and tax policies and the role of various US government agencies. Part two discusses export transactions in relation to 12 practical topics, including sales and distribution agreements, technology transfers, export controls and export tax planning. Part three examines the formation, financing and taxation of business ventures in foreign jurisdictions. Parts four through seven cover dispute settlement, currency management, US employees abroad and US regulation of foreign business activities.

Author : Charles H. Gustafson,Robert J. Peroni,Richard Crawford Pugh
Publisher : Unknown
Page : 1036 pages
File Size : 46,9 Mb
Release : 1997
Category : Business & Economics
ISBN : STANFORD:36105060175432

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

Author : Paul R. McDaniel,James R. Repetti,Diane M. Ring
Publisher : Unknown
Page : 0 pages
File Size : 45,8 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 : Philip Marc Raworth
Publisher : Thomson Professional Pub. Canada
Page : 360 pages
File Size : 42,7 Mb
Release : 1991
Category : Commercial law
ISBN : STANFORD:36105044516917

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Legal Guide to International Business Transactions by Philip Marc Raworth Pdf

Author : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 53,8 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 : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 41,7 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 : William P. Streng
Publisher : Unknown
Page : 706 pages
File Size : 51,5 Mb
Release : 1978
Category : Business & Economics
ISBN : UOM:35128000329555

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International Business Transactions Tax and Legal Handbook by William P. Streng Pdf

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 50,7 Mb
Release : 2021-05-14
Category : Law
ISBN : 9789403533643

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Exploring the Nexus Doctrine In International Tax Law by Ajit Kumar Singh Pdf

In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.

Author : Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 573 pages
File Size : 48,6 Mb
Release : 2018
Category : Income tax
ISBN : 0433495642

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International Taxation in Canada by Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie Pdf

Author : Aspatore, Inc
Publisher : Unknown
Page : 116 pages
File Size : 45,7 Mb
Release : 2012-11-01
Category : Law
ISBN : 0314286764

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Navigating Tax Issues in International Business Transactions by Aspatore, Inc Pdf