U S International Tax Planning And Policy

Author : Samuel C. Thompson
Publisher : Unknown
Page : 696 pages
File Size : 41,8 Mb
Release : 2007
Category : Business & Economics
ISBN : STANFORD:36105064179836

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U.S. International Tax Planning and Policy by Samuel C. Thompson Pdf

To access the 2010 Supplemental Materials, click here. This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions and addresses such issues as the U.S. taxation of a branch or U.S. subsidiary owned by a foreign corporation. Part III considers outbound transactions and deals with the U.S. taxation of foreign corporations controlled by U.S. persons. This part also addresses the rules regarding transfer pricing between commonly controlled entities, such as a U.S. parent corporation and its foreign subsidiary. Part IV focuses on cross-border mergers and acquisitions. Particular attention is given to the role of Section 367 on cross border reorganizations. The last sections of most chapters briefly discuss the manner in which South Africa, which has recently reformed its international tax system, addresses the issues presented in the chapter. From a tax planning standpoint, the U.S. tax advisor should have a basic understanding of the interface between the U.S. and foreign tax system involved in the transaction, and these discussions illustrate the interface between two sophisticated systems: the U.S. and South Africa.

Author : Daniel N. Shaviro
Publisher : Oxford University Press
Page : 242 pages
File Size : 41,6 Mb
Release : 2014-04
Category : Law
ISBN : 9780199359752

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Fixing U.S. International Taxation by Daniel N. Shaviro Pdf

Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.

Author : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 51,5 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 : Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 45,9 Mb
Release : 2019-01-14
Category : Law
ISBN : 9789403501727

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International Tax Primer by Brian J. Arnold Pdf

Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive, and continuing issues concerning the digital economy. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of nonresidents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. An extensive glossary of international tax terms is included. With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.

Author : Joel D. Kuntz
Publisher : Unknown
Page : 128 pages
File Size : 55,9 Mb
Release : 1991
Category : Aliens
ISBN : LCCN:91065051

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U.S. International Taxation by Joel D. Kuntz Pdf

Author : Denis A. Kleinfeld,Marshall J. Langer,Edward J. Smith
Publisher : Practising Law Inst
Page : 1735 pages
File Size : 45,6 Mb
Release : 2000
Category : Law
ISBN : 0872241289

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Langer on Practical International Tax Planning: Focus on tax planning by Denis A. Kleinfeld,Marshall J. Langer,Edward J. Smith Pdf

Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.

Author : Mindy Herzfeld
Publisher : Unknown
Page : 0 pages
File Size : 41,9 Mb
Release : 2023
Category : Corporations, Foreign
ISBN : 1685618065

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International Taxation in a Nutshell by Mindy Herzfeld Pdf

"This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated with the most up-to-date discussion of recent regulatory guidance interpreting the significant changes to the U.S. international tax rules introduced by the 2017 tax act. It also includes a discussion of how the newly enacted U.S. book minimum tax interacts with the international tax rules. Referenced throughout are the global tax developments of recent years and how those rules and proposals interact with the U.S. international tax regime. In addition to providing a survey of the technical rules, the book also offers insight into tax planning considerations and how these have been impacted by U.S. and global developments. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In today’s world, it is crucial for those involved in business and investment activities to understand the tax consequences of cross-border flows. The author’s career spans the academic and private sectors, and she has used her experiences to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts." -- Publisher.

Author : Alberto Giovannini,R. Glenn Hubbard,Joel Slemrod
Publisher : University of Chicago Press
Page : 336 pages
File Size : 52,6 Mb
Release : 2007-12-01
Category : Business & Economics
ISBN : 9780226297033

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Studies in International Taxation by Alberto Giovannini,R. Glenn Hubbard,Joel Slemrod Pdf

As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies. The contributors to this volume are Rosanne Altshuler, Alan J. Auerbach, Neil Bruce, Timothy Goodspeed, Roger H. Gordon, Harry Grubert, Bronwyn H. Hall, David Harris, Kevin Hassett, James R. Hines Jr., Roy D. Hogg, Joosung Jun, Jeffrey K. Mackie-Mason, Jack M. Mintz, Randall Morck, John Mutti, T. Scott Newlon, James M. Poterba, Joel Slemrod, Deborah Swenson, G. Peter Wilson, and Bernard Yeung.

Author : William C. Gifford,William P. Streng
Publisher : Unknown
Page : 760 pages
File Size : 45,6 Mb
Release : 1979
Category : Business & Economics
ISBN : MINN:31951002609236H

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International Tax Planning by William C. Gifford,William P. Streng Pdf

Author : Adam Starchild
Publisher : Springer Science & Business Media
Page : 154 pages
File Size : 44,7 Mb
Release : 2013-06-29
Category : Business & Economics
ISBN : 9789401744720

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Tax Planning for Foreign Investors in the United States by Adam Starchild Pdf

If you arenot a citizen or resident of the United States (U.S.) and you are contemplating either making or expanding an investment in the U .S., either for yourself as an individual or for a business, you arenot alone. The U.S. is the country of first choice for many foreign investors. This is due to the fact that the U.S. offers foreign investors many advantages, some ofwhich are in short supply in today's world. The primary advantage that the U.S. affords foreign investorsisthat it endorses the economic concept of free enterprise. While it is true that the Federal and state governments have interfered with the private economy to some extent, the prevailing economic philosophy in the U .S. remains laissez faire. History has taught the U.S. that the market place allocates the finite resources of a country betterthan the government, and the advantagesoftbis philosophy have not been overlooked by foreign investors. Another attractive feature of the U .S. as an investment site is its political stability. The present form of constitutional government has presided for over 200 years, and this history provides foreign investors with a measure of security which is absent elsewhere.

Author : Robert Feinschreiber
Publisher : Aspen Publishers
Page : 416 pages
File Size : 50,7 Mb
Release : 1977
Category : Conflict of laws
ISBN : UCAL:B4316292

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International Tax Planning Today by Robert Feinschreiber Pdf

Author : National Research Council,Board on Science, Technology, and Economic Policy
Publisher : National Academies Press
Page : 169 pages
File Size : 46,8 Mb
Release : 1998-02-05
Category : Political Science
ISBN : 9780309063685

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Borderline Case by National Research Council,Board on Science, Technology, and Economic Policy Pdf

The growing integration of world markets for capital and goods, coupled with the rise of instantaneous worldwide communication, has made identification of corporations as "American," "Dutch," or "Japanese" extremely difficult. Yet tax treatment does depend of where a firm is chartered. And, as Borderline Case documents, there is little doubt that tax rules for firms doing business in several nationsâ€"firms that account for more than three-quarters of corporate R&D spending in the United Statesâ€"have substantial effects on corporate decisionmaking and, ultimately, U.S. competitiveness. This book explores the impact of the U.S. tax code and its incentives on the international activities of U.S.- and foreign-based firms: basic research outlays, expenditures on product and process development, and plant and equipment investment. The authors include industry experts from large multinational firms in technology and pharmaceuticals, academic researchers who have explored the quantitative impact of tax provisions on R&D, and tax policy analysts who have examined international tax rules in the broader context of tax reform. These experts look at how corporate investment and R&D are shaped by specific tax provisions, such as the definition of taxable income, relative tax burdens on domestic and foreign business, taxation of earnings repatriated to the United States, deductibility of expenses of worldwide operations, and U.S. corporate taxes relative to other countries. The volume explores prescriptions and prospects for tax reform and reviews major reform proposals and their implications for the behavior of multinational business.

Author : M.J. Langer
Publisher : Unknown
Page : 128 pages
File Size : 42,6 Mb
Release : 1985
Category : Electronic
ISBN : OCLC:1182813702

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Practical international tax planning by M.J. Langer Pdf

Publication surveying all aspects of international tax planning including the effective use of foreign financial centres and tax havens. Subjects deal with are: the legal framework of international tax planning; tax planning in the U.S.A. and outside the U.S.A.; offshore bases outside the U.S.A.; fundamentals of international taxation; import practice. Other subjects are: foreign investment in U.S. real estate and minimizing FIRPTA tax on dispositions of U.S. real estate; offshore banks and trust companies; foreign anti-avoidance measures, etc. The book takes into account the impact of the 1986 Tax Reform Act as well as other changes resulting from new income tax treaties, mutual assistance treaties, and significant changes in the laws of other countries and other revisions.

Author : Ernest R. Larkins
Publisher : John Wiley & Sons
Page : 456 pages
File Size : 49,8 Mb
Release : 2003-11-20
Category : Business & Economics
ISBN : 9780471482819

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International Applications of U.S. Income Tax Law by Ernest R. Larkins Pdf

A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!

Author : Amanda D. Johnson
Publisher : WorldTrade Executive, Inc.
Page : 170 pages
File Size : 44,5 Mb
Release : 2005
Category : Business & Economics
ISBN : 1893323706

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Using Treaties and Holding Companies for Latin American Tax Planning by Amanda D. Johnson Pdf

Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.