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 Practical Guide to U S Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2015 with total page 0 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 Introduction to United States International Taxation written by Paul R. McDaniel and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. 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.
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 Taxation of International Transactions written by Charles H. Gustafson and published by West Academic Publishing. This book was released on 2001 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 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 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 International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
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 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 U S International Taxation written by Joel D. Kuntz and published by . This book was released on 1991 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Federal Taxation of International Transactions written by Richard L. Kaplan and published by . This book was released on 1988 with total page 700 pages. Available in PDF, EPUB and Kindle. Book excerpt: Monograph intended for teaching law students to the federal income taxation of international transactions. Attention is given to tax policy considerations, political as well as economic ramifications and alternative statutory formulations.
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 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 United States International Taxation written by Allison Christians and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross- border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.
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.
