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 Circular A Agricultural Employer s Tax Guide written by and published by . This book was released on 1992 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Self employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book U S Income Taxation of Foreign Corporations written by Jessica L. Katz and published by . This book was released on 2000 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book A Summary of Administration Recommendations on U S Taxation of Foreign Income and Foreign Persons written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 1974 with total page 56 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 Income Taxation of Foreign Corporations written by Charles T. Plambeck and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ...describes the Internal Revenue Code provisions applicable to foreign corporations. The United States asserts jurisdiction to tax foreign corporations only if they are engaged in business in the United States or receive income from sources within the United States. Foreign corporations that are engaged in a trade or business in the United States are subject to net-basis income tax under §882 on any of their income that is “effectively connected” with that business. Such corporations also may be subject to the branch taxation regime of §884, which is described in 6480 T.M., The Branch-Related Taxes of Section 884. In addition, all foreign corporations, whether or not engaged in a business in the United States, are subject to gross-basis tax under §881 on certain types of U.S.-source income — primarily investment income, such as interest and dividends — that are not “effectively connected” with a U.S. business.

Download or read book Tax Effects of Conducting Foreign Business Through Foreign Corporations written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1961 with total page 64 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 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 A Guide to United States Taxation of Foreign Corporations and Individuals written by Arthur Young International and published by . This book was released on 1976 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book U S Income Taxation of Foreign Corporations and Nonresident Aliens written by Sidney I. Roberts and published by . This book was released on 1967 with total page 496 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 U S Income Taxation of Foreign Corporations written by Jessica L. Katz and published by . This book was released on 2008-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "... describes the Internal Revenue Code provisions applicable to foreign corporations. The United States asserts jurisdiction to tax foreign corporations only if they are engaged in business in the United States or receive income from sources within the United States. Foreign corporations that are engaged in a trade or business in the United States are subject to net-basis income tax under [section] 882 on any of their income that is "effectively connected" with that business. Such corporations also may be subject to the branch taxation regime of [section] 884, which is described in 909 T.M.,the Branch-related taxes of section 884. In addition, all foreign corporations, whether or not engaged in a business in the United States, are subject to gross-basis tax under [section] 881 on certain types of U.S.--source income--primarily investment income, such as interest and dividends--that are not "effectively connected" with a U.S. business. "

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 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 Federal Income Tax Project written by American Law Institute and published by . This book was released on 1987 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proposals on United States taxation of foreign persons and of the foreign income of United States persons.