Download or read book The Law of Foreign Corporations and Taxation of Corporations Both Foreign and Domestic written by Joseph Henry Beale and published by . This book was released on 1904 with total page 1208 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Laws Applicable to Foreign Corporations written by Pennsylvania. Bureau of Corporation Taxes and published by . This book was released on 1953* with total page 7 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 U S Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Corporations Doing Business in Other States written by Harry Albert Haring and published by . This book was released on 1927 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Law of Foreign Corporations written by William Law Murfree and published by . This book was released on 1893 with total page 436 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Income Taxation of Foreign Corporations and Non resident Aliens written by Sidney I. Roberts and published by . This book was released on 1966 with total page 1132 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The International Income Tax Rules of the United States written by Michael J. McIntyre and published by MICHIE. This book was released on 1989 with total page 686 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 Department of the Treasury s Report on Issues Related to the Compliance with U S Tax Laws by Foreign Firms Operating in the United States written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1992 with total page 178 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Taxation of Corporations in New York written by Henry Montefiore Powell and published by . This book was released on 1914 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book US Taxation of Foreign Income written by Gary Clyde Hufbauer and published by Peterson Institute. This book was released on 2007 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U S Tax Aspects of Doing Business Abroad written by Michael L. Moore and published by . This book was released on 1978 with total page 388 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 Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.
Download or read book Federal Income Taxation of U S Branches of Foreign Corporations written by Fred B. Brown and published by . This book was released on 2008 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: Foreign corporations conduct U.S. business activities either through U.S. subsidiaries or U.S. branches. A U.S. subsidiary of a foreign corporation generally is taxed as any other domestic corporation, that is, as a separate taxable entity apart from its foreign parent. In contrast, a U.S. branch of a foreign corporation is not treated as a separate taxable entity; instead, the Code and regulations employ a set of special rules that allocate and apportion to the U.S. branch a portion of the foreign corporation's income in order to determine the net income subject to U.S. tax.The rules used for taxing U.S. branch activities are problematic in a number of respects. They fail in some cases to accurately reflect the income produced by U.S. branch activities. In addition, these rules may differ substantially from methods employed by other countries to assign income to U.S. activities, thereby raising the risk that a portion of a foreign corporation's income will be taxed by two counties. The rules for U.S. branches also appear to add to the complexity of the tax law. The end result of a separate entity method for U.S. subsidiaries and different rules for U.S. branches is unwarranted variation in tax treatment based on the form of business used by a foreign corporation. This article considers the use of the separate entity method for taxing U.S. branches of foreign corporations, focusing on four fundamental policy concerns in the taxation of international business operations: accurate reflection of income, tax administration and simplicity, harmonizing different countries' tax laws, and neutrally taxing different forms of conducting businesses. The article recommends that the separate entity method be used for U.S. branches of foreign corporations, provided its use continues for U.S. subsidiaries.
