Download or read book CFCs investment of Earnings in United States Property written by Philip Fried (Lawyer) and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investments of earnings and profits by controlled foreign corporations in United States property. This Portfolio discusses the circumstances under which such investments may result in the taxation to the company's U.S. shareholders of a portion of the company's earnings and profits, and it explains the rules governing the computation of such income inclusion. It describes the possibility of unexpected results from the operation of the §956 rules, and it suggests planning possibilities to avoid pitfalls. Among the matters discussed are the definition of the term "United States property" and the exceptions thereto; calculations of the amount of a controlled foreign corporation's earnings and profits invested in United States property and the effect of distributions on such calculations; special rules regarding the taxation of U.S. shareholders, including the applicable foreign tax credit rules; and tax planning opportunities."

Download or read book International Income Taxation written by Robert J. Peroni and published by CCH. This book was released on 2008 with total page 2356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.

Download or read book Tax Management Portfolios written by and published by . This book was released on 2001 with total page 122 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Reports of the United States Tax Court written by United States. Tax Court and published by . This book was released on 2011-07 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Disregarded Entities written by Howard E. Abrams and published by . This book was released on 2006 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... discusses entities that are recognized as having a legal status separate from their owners for certain purposes but are totally ignored for federal income tax purposes. The three types of disregarded entities are entities disregarded under the elective classification regime, qualified S corporation subsidiaries, and qualified real estate investment trust subsidiaries. For each type of entity, qualification, formation, conversion, operation, and termination issues are addressed along with use of the entity in specific contexts including corporate reorganizations, partnership transactions, and like-kind exchanges. Application of specific provisions such as the at-risk rules and the cancellation of indebtedness provisions are discussed. Use of disregarded entities in cross-border transactions and their impact on the direct and indirect foreign tax credit also are described.

Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

Download or read book Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and published by . This book was released on 2008 with total page 1058 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Income Tax Law Training for Revenue Agents Foreign affairs written by United States. Internal Revenue Service and published by . This book was released on 1966 with total page 146 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Fiscal Year 2016 Analytical Perspectives Budget of the U S Government written by and published by Government Printing Office. This book was released on 2015-02-02 with total page 412 pages. Available in PDF, EPUB and Kindle. Book excerpt: Contains analyses that are designed to highlight specified subject areas or provide other significant presentations of budget data that place the budget in perspective. This volume includes economic and accounting analyses; information on Federal receipts and collections; analyses of Federal spending; detailed information on Federal borrowing and debt; baseline or current services estimates; and other technical presentations.

Download or read book Tax reform act of 1975 written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 1976 with total page 556 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Internal Revenue Bulletin written by United States. Internal Revenue Service and published by . This book was released on 1998 with total page 584 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Package X written by United States. Internal Revenue Service and published by . This book was released on 1996 with total page 552 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book General Explanation of Tax Legislation Enacted in 1997 written by United States. Congress. Joint Committee on Taxation and published by Congress. This book was released on 1997 with total page 580 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Miscellaneous Revenue Issues written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures and published by . This book was released on 1990 with total page 804 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation written by Joseph Isenbergh and published by CCH. This book was released on 2006 with total page 966 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book An Examination of U S Tax Policy and Its Effects on the International Competitiveness of U S owned Foreign Operations written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2004 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: