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Author : Boris I. Bittker,Lawrence F. Ebb
Publisher : Unknown
Page : 616 pages
File Size : 52,5 Mb
Release : 1968
Category : Aliens
ISBN : STANFORD:36105044134885
Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 48,6 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827
Author : United States. Congress. Senate. Committee on Finance
Publisher : Unknown
Page : 56 pages
File Size : 50,8 Mb
Release : 1974
Category : Aliens
ISBN : UOM:39015076085441
Author : Gary Clyde Hufbauer
Publisher : Peterson Institute
Page : 340 pages
File Size : 42,7 Mb
Release : 2007
Category : Corporations, Foreign
ISBN : 9780881325737
Author : James R. Repetti,Diane M. Ring,,Stephen Shay
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 45,9 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 : American Law Institute
Publisher : Unknown
Page : 546 pages
File Size : 53,5 Mb
Release : 1987
Category : Aliens
ISBN : STANFORD:36105061894619
Proposals on United States taxation of foreign persons and of the foreign income of United States persons.
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 40 pages
File Size : 53,8 Mb
Release : 2024-06-16
Category : Electronic
ISBN : STANFORD:36105127906399
Author : Joseph Isenbergh
Publisher : CCH
Page : 966 pages
File Size : 53,9 Mb
Release : 2006
Category : Aliens
ISBN : 0808016164
Author : Robert Meldman,Michael S. Schadewald
Publisher : Springer
Page : 408 pages
File Size : 48,6 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 : United States. Internal Revenue Service
Publisher : Unknown
Page : 32 pages
File Size : 45,8 Mb
Release : 1990
Category : Annuities
ISBN : UFL:31262045586780
Author : Robert E. Meldman,Michael Schadewald
Publisher : Springer
Page : 516 pages
File Size : 54,9 Mb
Release : 2000-06-22
Category : Business & Economics
ISBN : STANFORD:36105060329153
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 : Joseph Isenbergh,Bret Wells
Publisher : Unknown
Page : 0 pages
File Size : 46,9 Mb
Release : 2023-12-28
Category : Electronic
ISBN : 080805886X
International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners. International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area. It shows the practitioner how to: -Structure international corporate transactions for maximum benefit. -Minimize liability under applicable laws and treaties. -Practice effectively and compliantly within the complex web of legal authority. The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts: Part I Elements of International Taxation Part II U.S. Taxation of Nonresident Aliens and Foreign Corporations Part III U.S. Taxation of Foreign Income Part IV Foreign Currency Questions Part V International Corporate Reorganizations Part VI Income Tax Treaties Part VII Withholding in International Taxation Part VIII International Transfer Taxation Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 24 pages
File Size : 48,6 Mb
Release : 1979
Category : Double taxation
ISBN : UFL:31262085183746
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 16 pages
File Size : 40,8 Mb
Release : 1986
Category : Double taxation
ISBN : MINN:31951002940406I
Author : Michael J. McIntyre
Publisher : MICHIE
Page : 686 pages
File Size : 46,9 Mb
Release : 1989
Category : Aliens
ISBN : MINN:31951D01839837H
