Download Full eBooks in PDF
U S International Taxation Book in PDF, ePub and Kindle version is available to download in english. Read online anytime anywhere directly from your device. Click on the download button below to get a free pdf file of U S International Taxation book. This book definitely worth reading, it is an incredibly well-written.
Author : Daniel N. Shaviro
Publisher : Oxford University Press
Page : 242 pages
File Size : 40,7 Mb
Release : 2014-04
Category : Law
ISBN : 9780199359752
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 : Allison Christians,Samuel A. Donaldson,Philip F. Postlewaite
Publisher : Unknown
Page : 0 pages
File Size : 40,5 Mb
Release : 2011
Category : Aliens
ISBN : 1422480313
This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross- border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.
Author : Paul R. McDaniel,James R. Repetti,Diane M. Ring
Publisher : Unknown
Page : 0 pages
File Size : 42,6 Mb
Release : 2014
Category : Aliens
ISBN : 9041136568
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 F. Postlewaite,Mitchell B. Weiss
Publisher : Unknown
Page : 128 pages
File Size : 48,5 Mb
Release : 2022-02
Category : Electronic
ISBN : 1531011160
Author : Joel D. Kuntz
Publisher : Unknown
Page : 128 pages
File Size : 52,9 Mb
Release : 1992
Category : Aliens
ISBN : 079131135X
Author : Philip F. Postlewaite,Stephanie Renee Hoffer
Publisher : Unknown
Page : 0 pages
File Size : 54,7 Mb
Release : 2010
Category : Corporations, Foreign
ISBN : 1594607974
This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.
Author : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 51,5 Mb
Release : 1997
Category : Business & Economics
ISBN : STANFORD:36105062261552
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 : 50,9 Mb
Release : 2021-07-07
Category : Law
ISBN : 9789403523903
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 : Anonim
Publisher : Unknown
Page : 12 pages
File Size : 51,9 Mb
Release : 1988
Category : Income tax
ISBN : MINN:31951D013914451
Author : Richard L. Doernberg
Publisher : West Publishing Company
Page : 580 pages
File Size : 49,7 Mb
Release : 2001
Category : Business & Economics
ISBN : STANFORD:36105061756206
After an introduction to the fundamentals of U.S. international taxation, the U.S. activities of foreign taxpayers and the foreign activities of U.S. citizens and residents are addressed. Special U.S. international tax provisions creating incentives and disincentives for certain conducts or forms of business transactions are looked at and the effect of U.S. transfer taxes (estate, gift and generation-skipping tax) on both resident and nonresident aliens is dealt with.
Author : Paul R. McDaniel,Hugh J. Ault
Publisher : Springer
Page : 232 pages
File Size : 51,8 Mb
Release : 1981-06-17
Category : Business & Economics
ISBN : STANFORD:36105043742290
This book presents the basic priciples and rules of the United States international tax system in a relatively brief form. The purpose is to provide an overview of 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 : Daniel N. Shaviro
Publisher : Oxford University Press
Page : 256 pages
File Size : 51,5 Mb
Release : 2014-01-08
Category : Law
ISBN : 9780199359769
International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 28 pages
File Size : 53,5 Mb
Release : 1990
Category : Double taxation
ISBN : UFL:31262045595427
Author : Joel D. Kuntz
Publisher : Unknown
Page : 128 pages
File Size : 44,9 Mb
Release : 1991
Category : Aliens
ISBN : LCCN:91065051
Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 47,7 Mb
Release : 2021-05-14
Category : Law
ISBN : 9789403533643
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.