Download or read book Smith and Another V Commissioner of Internal Revenue 151 TC No 5 written by and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Judgment by the United States Tax Court, judgment date 18 September 2019. In this case the Court granted motions for summary judgment for the IRS, finding the taxpayers' CFC in Hong Kong was not a domestic corporation or a qualified foreign corporation and thus that the CFC's distribution to the taxpayers was not qualified dividend income but was taxable to the taxpayers at ordinary income rates. The Tax Court also found that the taxpayers had received a constructive dividend from a Cypriot CFC on the cancellation of an account receivable balance owned to that CFC.
Download or read book Federal Taxation of Income Estates and Gifts written by Boris I. Bittker and published by Warren Gorham & Lamont. This book was released on 1999 with total page 852 pages. Available in PDF, EPUB and Kindle. Book excerpt: Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: 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 U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
Download or read book The Cannabis Business written by Charles S. Alovisetti and published by Routledge. This book was released on 2020-12-29 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the largely illicit cannabis market transitions to a legal, regulated industry, the "canna-curious" and experienced industry participants alike are experiencing the harsh truth: Making a fortune in the legal cannabis industry is a challenge made even more difficult by a complex patchwork of state and federal laws. The Cannabis Business clears the confusion around topics such as the distinction between hemp and cannabis and why it matters for consumers and regulators, why CBD isn’t completely legal in the U.S., why and how states differ in their licensing processes, and how deal structuring is impacted by state regulations. Written by attorneys from the nation’s leading cannabis law and policy firm, this comprehensive primer on all things cannabis law is a must-have for anyone seeking to understand the major practical legal issues facing the cannabis industry in the U.S.
Download or read book Tax Evasion and the Law written by Sam Bourton and published by Taylor & Francis. This book was released on 2024-06-18 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a critical and contemporary evaluation of the laws and enforcement policies pertaining to tax evasion in the United Kingdom (UK) and United States (US). Since the inception of taxes, revenue collection authorities around the world have attempted to address the seemingly perennial problem of individuals evading their tax liabilities. The financial crisis has shone a new light on the issue with an increased interest in using the criminal justice system as a means of addressing it in the UK. In sharp contrast to the UK, the US has a strong record of prosecuting crimes of tax evasion, whether committed by individuals or professional corporate facilitators. Providing an evaluation of the UK’s tax evasion laws and enforcement policy, through a comparative approach, this work highlights insights provided by the US experience. In so doing, the book explores the interconnections between tax evasion and money laundering, identifying best practices, omissions, and areas for reform. The work will be a valuable resource for researchers, academics, and policy-makers working in the areas of financial crime, financial law, accountancy and criminal justice.
Download or read book Records and Briefs of the United States Supreme Court written by and published by . This book was released on 1832 with total page 1238 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Statement of Procedural Rules written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 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 1958 with total page 1376 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book McNamara V Commissioner of Internal Revenue written by and published by . This book was released on 1953 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Reports of the Tax Court of the United States written by United States. Tax Court and published by . This book was released on 1971 with total page 1242 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Court Memorandum Decisions written by Commerce Clearing House and published by . This book was released on 2008 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Contains the full texts of all Tax Court decisions entered from Oct. 24, 1942 to date, with case table and topical index.
Download or read book Coordinated Examination Program CEP written by and published by . This book was released on 1991 with total page 2 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book General Revenue Revision written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1953 with total page 1518 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Income Tax Treatment of Cooperatives Handling of losses written by Donald A. Frederick and published by . This book was released on 1993 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Johnson V Commissioner of Internal Revenue written by and published by . This book was released on 1982 with total page 74 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book United States Government Publications Monthly Catalog written by and published by . This book was released on 1947 with total page 1700 pages. Available in PDF, EPUB and Kindle. Book excerpt:
