Download or read book Practical Guide to U S Taxation of International Transactions 13th written by Michael Schadewald and published by . This book was released on 2022-08-14 with total page 920 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.
Download or read book Practical Guide to U S Taxation of International Transactions written by Robert J. Misey and published by . This book was released on 2007-09-01 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Practical Guide to United States Taxation of International Transactions written by Robert E. Meldman and published by Kluwer Law International. This book was released on 2003 with total page 501 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Excellent description of most important concepts and issues concerned with U.S. taxation of international transactions. Provides illustrative examples, tables and charts to help reader understand complexities involved. Concisely and clearly written for business managers, accountants and attorney involved in international business."
Download or read book Practical Guide to U S Taxation of International Transactions written by Robert J. Misey and published by . This book was released on 2007-09-01 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Practical Guide to U S Taxation of International Transactions written by Robert E. Meldman and published by Springer. This book was released on 2000-06-22 with total page 516 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.).
Download or read book Practical Guide to U S Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2006 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Practical Guide to US Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2006-02-01 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a free Instructor's Guide for teachers that adopt the textbook.
Download or read book Taxation of International Transactions written by ROBERT J.. BROWN PERONI (KAREN B.. FLEMING, J. CLIFTON.) and published by West Academic Publishing. This book was released on 2021-07-06 with total page 1212 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools, and schools of management, this significantly revised casebook (formerly Gustafson, Peroni, and Pugh's Taxation of International Transactions) outlines the determination of U.S. income tax liabilities resulting from international transactions and the issues attending administration of the U.S. international tax rules. Textual discussion, cases, rulings, and problems guide students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, as well as those confronting U.S. individuals and entities seeking to derive income abroad. It covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules. This book fully covers all the significant provisions of the Tax Cuts and Jobs Act of 2017 and subsequent regulatory and administrative guidance regarding those provisions, including the revised foreign tax credit limitations, the participation exemption system in Section 245A, and the GILTI and FDII provisions.
Download or read book Taxation of International Transactions written by Charles H. Gustafson and published by West Academic Publishing. This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Download or read book International Tax Controversies written by Philip R. West and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the U.S. Justice Department taking an ever-closer look at cross-border transactions and their tax implications, the new International Tax Controversies: A Practical Guide provides a detailed roadmap to how to prepare for a tax audit that involves an international component. Creating and retaining the proper transaction-related documentation, and understanding what additional documentation might be needed for an international examination, is vital to a successful audit. International Tax Controversies describes the process of how an international audit proceeds, including providing information on: How the IRS audit team is chosenWhat the limits are of the scope of the examinationThe type of examination that will be conducted and the kinds of documents that will need to be provided by the taxpayer and third partiesThe kinds of enforcement procedures that may be broughtIn international tax situations, there are often conflicting positions taken by the U.S. Internal Review Service and a non-U.S. tax authority. Tax treaties containing mutual agreement procedures (MAPs) are often invoked to protect the taxpayer from paying double taxes. International Tax Controversies describes the process by which MAPs may be invoked and a binding resolution created. As most disagreements between international taxing entities involve transfer pricing issues, there is generally an opportunity to obtain an advance pricing agreement (APA) to protect the taxpayer. International Tax Controversies analyzes the APA process, providing a detailed guide on facilitating the process for your client. It also describes the many tax information exchange treaties and agreements that the U.S. has entered into, and the impact they have had on the U.S. taxpayer.
Download or read book Practical Guide to U S Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Download or read book Taxation of International Transactions written by Charles H. Gustafson and published by . This book was released on 1995 with total page 860 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing in the US written by Felix I. Lessambo and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Taxation of International Transactions written by Samuel C. Thompson, Jr. and published by . This book was released on 1995-06-01 with total page 65 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Taxation Us Taxation of Foreign Persons foreign Income 2023 written by Joseph Isenbergh and published by . This book was released on 2022-12-28 with total page 2200 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Taxation U S Taxation of Foreign Persons and Foreign Income 2022 written by Joseph Isenbergh and published by . This book was released on 2021-12-30 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Taxation Us Taxation of Foreign Persons Foreign Income 2024 written by Joseph Isenbergh and published by . This book was released on 2023-12-28 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
