Download or read book International Taxation written by Joseph Isenbergh and published by CCH. This book was released on 2006 with total page 918 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation written by Joseph Isenbergh and published by . This book was released on 2007-12 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2008 Supplement updates the four volume, International Taxation: U.S. Taxation of Foreign Persons and Foreign Income. The parent volume offers an all-inclusive, easy-to-follow discussion of the United States tax regime as applied to foreign transactions. It reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies that can be put to good use right away. The 2008 Supplement was authored by CCH Tax Law Editors.

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.

Download or read book International Taxation U S Taxation of Foreign Persons and Foreign Income written by J. Isenbergh and published by . This book was released on 2000 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Treatise on international aspects of US individual and corporate income taxation. Explains the basic principles of US international taxation (residence, source etc) and contains detailed explanations of all aspects of outbound and inbound transactions. Part 1: Basic elements of international taxation; Part 2: Inbound U.S. taxation ; Part 3: Outbound U.S. taxation; Part 4: Income tax treaties.

Download or read book International Taxation written by Joseph Isenbergh and published by Thomson West. This book was released on 2005 with total page 322 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation discusses international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. Divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.Summary of Contents" Part I: Basic Elements of International TaxationChapter1. U.S. Taxation in the International Setting2. Nationality and Residence for Taxation3. The Source of Income4. International Transfer Pricing" Part II: Inbound U.S. Taxation5. U.S. Taxation of Foreign Persons: Passive Income6. The Meaning of a U.S. "Trade or Business"7. "Effectively Connected" Income8. Gains from Sales of U.S. Real Property9. The Branch Profits Tax" Part III: Outbound U.S. Taxation10. Outbound Taxation in Overview11. The Foreign Tax Credit: Background and Overview12. The Foreign Tax Credit: Creditable Foreign Taxes13. The Credit Limitation of Section 90414. The Indirect Foreign Tax Credit15. Grand Overview of Dividends from Foreign Corporations16. Controlled Foreign Corporations: Subpart F17. Controlled Foreign Corporations: Section 124818. Passive Foreign Investment Companies (PFICs)19. International Corporate Reorganizations20. U.S. Citizens Abroad21. Income Tax Incentives for Exports" Part IV: Income Tax Treaties22. Income Tax Treaties in Overview23. Residence in Income Tax Treaties24. Business Profits - Permanent Establishments25. Compensation for Personal Services26. Interest, Dividends, Royalties, Rents, and Other Gains27. The Rise and Fall of Treaty Tax Shelters: Sandwiches, Conduits, and the Treasurys Response" Table of Cases" Index

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 International Taxation written by Joseph Isenbergh and published by . This book was released on 2015-12-24 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation is a comprehensive four volume 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 CorporationsPart III U.S. Taxation of Foreign IncomePart IV Foreign Currency QuestionsPart V International Corporate ReorganizationsPart VI Income Tax TreatiesPart 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 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 International Taxation written by Joseph Isenbergh and published by Aspen Publishers. This book was released on 1998-10-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation written by Joseph Isenbergh and published by . This book was released on 2009-11 with total page 790 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 International Taxation written by Joseph Isenbergh and published by . This book was released on 2015-12-21 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation is a comprehensive four volume 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

Download or read book International Taxation written by Joseph Isenbergh and published by . This book was released on 2013-12-15 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation U S Taxation of Foreign Persons and Foreign Income 2021 written by Joseph Isenbergh and published by . This book was released on 2021-02-15 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 written by Joseph Isenbergh and published by . This book was released on 2016-12-21 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 Supplement updates the four volume, International Taxation: U.S. Taxation of Foreign Persons and Foreign Income. The parent volume offers an all-inclusive, easy-to-follow discussion of the United States tax regime as applied to foreign transactions. It reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies that can be implemented immediately. International Taxation provides guidance to attorneys or accountants in tax or general practice who, when faced with an international tax question, need assistance through the sprawling and amorphous assemblage of laws and regulation in this area. It is also an excellent resource for international tax experts and consultants.It shows the practitioner how to:-Structure international corporate transactions for maximum benefit. -Minimize liability under applicable treaties, U.S. law, and applicable foreign law. -Practice effectively within the often inconsistent web of legal authority. -Covering both inbound and outbound transactions, author Joseph Isenbergh unfailingly reduces even the most complicated issues to clear, understandable strategies, and then provides unparalleled, incisive analysis.

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.