U S Income Taxation Of Foreign Corporations And Non Resident Aliens

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U. S. Income Taxation of Foreign Corporations and Non-resident Aliens

Author : Sidney I. Roberts,William Clements Warren
Publisher : Unknown
Page : 1112 pages
File Size : 42,7 Mb
Release : 1966
Category : Aliens
ISBN : MINN:31951D004760382

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U. S. Income Taxation of Foreign Corporations and Non-resident Aliens by Sidney I. Roberts,William Clements Warren Pdf

U.S. Tax Guide for Aliens

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 48,9 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827

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U.S. Tax Guide for Aliens by Anonim Pdf

U.S. Income Taxation of Foreign Corporations and Nonresident Aliens

Author : Sidney I. Roberts
Publisher : Unknown
Page : 0 pages
File Size : 49,5 Mb
Release : 1966
Category : Electronic
ISBN : OCLC:1262804180

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U.S. Income Taxation of Foreign Corporations and Nonresident Aliens by Sidney I. Roberts Pdf

Extensive handbook on the taxation of foreign corporations and nonresidents in the USA. Chapters include: general principles, tax patterns of foreign taxpayers, the foreign tax credit, definitions, residence and citizenship, trade or business within the United States, sources of income, withholding of tax at source, tax treaties, corporations used to avoid income tax on shareholders, and returns.

Income Taxation of Nonresident Aliens and Foreign Corporations

Author : Sidney I. Roberts,William Clements Warren
Publisher : Unknown
Page : 148 pages
File Size : 48,6 Mb
Release : 1953
Category : Aliens
ISBN : STANFORD:36105063140920

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Income Taxation of Nonresident Aliens and Foreign Corporations by Sidney I. Roberts,William Clements Warren Pdf

A Practical Guide to U. S. Taxation of International Transactions

Author : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 55,5 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.

Withholding of Tax on Nonresident Aliens and Foreign Corporations

Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 36 pages
File Size : 50,8 Mb
Release : 1973
Category : Aliens
ISBN : HARVARD:32044032292211

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Withholding of Tax on Nonresident Aliens and Foreign Corporations by United States. Internal Revenue Service Pdf

Introduction to United States International Taxation

Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 47,7 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.

Bulletin "N" (Rev.) 1947

Author : United States. Office of Internal Revenue
Publisher : Unknown
Page : 224 pages
File Size : 47,6 Mb
Release : 1947
Category : Aliens
ISBN : SRLF:A0014250336

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Bulletin "N" (Rev.) 1947 by United States. Office of Internal Revenue Pdf

Aspen Treatise for Introduction To United States International Taxation

Author : James R. Repetti,Diane M. Ring,Stephen E. Shay
Publisher : Aspen Publishing
Page : 369 pages
File Size : 41,8 Mb
Release : 2021-12-28
Category : Business & Economics
ISBN : 9781543827248

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Aspen Treatise for Introduction To United States International Taxation by James R. Repetti,Diane M. Ring,Stephen E. 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 international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: 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 U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.

United States Taxation of Foreign Income and Foreign Persons

Author : Boris I. Bittker,Lawrence F. Ebb
Publisher : Unknown
Page : 616 pages
File Size : 54,5 Mb
Release : 1968
Category : Aliens
ISBN : STANFORD:36105044134885

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United States Taxation of Foreign Income and Foreign Persons by Boris I. Bittker,Lawrence F. Ebb Pdf

U.S. Tax Aspects of Doing Business Abroad

Author : Michael L. Moore,Ronald N. Bagley
Publisher : Unknown
Page : 388 pages
File Size : 53,5 Mb
Release : 1978
Category : Corporations
ISBN : UCAL:B3454865

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U.S. Tax Aspects of Doing Business Abroad by Michael L. Moore,Ronald N. Bagley Pdf