Taxation Of International Transactions

Author : Michael S. Schadewald,Robert J. Misey
Publisher : Unknown
Page : 0 pages
File Size : 43,6 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 : 50,7 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 : Charles H. Gustafson,Robert J. Peroni,Richard Crawford Pugh
Publisher : West Academic Publishing
Page : 0 pages
File Size : 47,8 Mb
Release : 2011
Category : Casebooks
ISBN : 0314911715

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

Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.

Author : Charles H. Gustafson,Robert J. Peroni,Richard Crawford Pugh
Publisher : West Academic Publishing
Page : 1290 pages
File Size : 40,5 Mb
Release : 2001
Category : Business & Economics
ISBN : STANFORD:36105063986850

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

Author : Michael Schadewald,Misey Jr. Robert
Publisher : Unknown
Page : 920 pages
File Size : 49,7 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 : Charles H. Gustafson,Richard Crawford Pugh
Publisher : Unknown
Page : 860 pages
File Size : 48,9 Mb
Release : 1995
Category : Corporations, Foreign
ISBN : OCLC:37309095

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

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 448 pages
File Size : 43,9 Mb
Release : 2020-02-20
Category : Law
ISBN : 9789403510958

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International Taxation of Banking by John Abrahamson Pdf

Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.

Author : ROBERT J.. BROWN PERONI (KAREN B.. FLEMING, J. CLIFTON.),Karen Brown,J. Fleming
Publisher : West Academic Publishing
Page : 1212 pages
File Size : 50,7 Mb
Release : 2021-07-06
Category : Electronic
ISBN : 1683281047

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Taxation of International Transactions by ROBERT J.. BROWN PERONI (KAREN B.. FLEMING, J. CLIFTON.),Karen Brown,J. Fleming Pdf

Designed for use in law schools, business schools, and schools of management, this significantly revised casebook (formerly Gustafson, Peroni, and Pugh's Taxation of International Transactions) outlines the determination of U.S. income tax liabilities resulting from international transactions and the issues attending administration of the U.S. international tax rules. Textual discussion, cases, rulings, and problems guide students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, as well as those confronting U.S. individuals and entities seeking to derive income abroad. It covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules. This book fully covers all the significant provisions of the Tax Cuts and Jobs Act of 2017 and subsequent regulatory and administrative guidance regarding those provisions, including the revised foreign tax credit limitations, the participation exemption system in Section 245A, and the GILTI and FDII provisions.

Author : Robert E. Meldman,Michael Schadewald
Publisher : Springer
Page : 516 pages
File Size : 43,9 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 : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 42,9 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 : Robert J. Misey,Michael S. Schadewald
Publisher : Unknown
Page : 18 pages
File Size : 48,7 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 : Felix I. Lessambo
Publisher : iUniverse
Page : 363 pages
File Size : 52,7 Mb
Release : 2009
Category : Business & Economics
ISBN : 9780595633074

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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 : Jinyan Li,Arthur J. Cockfield,J. Scott Wilkie
Publisher : Unknown
Page : 573 pages
File Size : 41,7 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 : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 42,9 Mb
Release : 2012-12-06
Category : Business & Economics
ISBN : 9781461510710

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The International Taxation System by Andrew Lymer,John Hasseldine Pdf

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

Author : Michael S. Schadewald,Robert J. Misey, Jr.
Publisher : Unknown
Page : 104 pages
File Size : 40,9 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.