Aspen Treatise For Introduction To United States International Taxation
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Aspen Treatise For Introduction To United States International Taxation
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Author : James R. Repetti
language : en
Publisher: Aspen Publishing
Release Date : 2021-12-28
Aspen Treatise For Introduction To United States International Taxation written by James R. Repetti and has been published by Aspen Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-12-28 with Business & Economics categories.
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.
Introduction To United States International Taxation
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Author : Paul R. McDaniel
language : en
Publisher:
Release Date : 2014
Introduction To United States International Taxation written by Paul R. McDaniel and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Aliens categories.
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.
Introduction To United States International Taxation
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Author : James R. Repetti
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-07-07
Introduction To United States International Taxation written by James R. Repetti and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-07-07 with Law categories.
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.
Introduction To United States International Taxation
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Author : Paul McDaniel
language : en
Publisher: Springer
Release Date : 2014-04-20
Introduction To United States International Taxation written by Paul McDaniel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-04-20 with Business & Economics categories.
Introduction To United States International Taxation
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Author : Paul R. McDaniel
language : en
Publisher:
Release Date : 1977
Introduction To United States International Taxation written by Paul R. McDaniel and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1977 with Aliens categories.
This book presents the basic priciples and rules of the United States international tax system in a relatively brief form. The purpose is to provide an overview of 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.
Introduction To United States International Taxation
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Author : Paul McDaniel
language : en
Publisher: Springer
Release Date : 1998-02-15
Introduction To United States International Taxation written by Paul McDaniel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-02-15 with Business & Economics categories.
Advanced Introduction To International Tax Law
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Edward Elgar Publishing
Release Date : 2019
Advanced Introduction To International Tax Law written by Reuven S. Avi-Yonah and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Double taxation categories.
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
International Taxation In A Nutshell
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Author : Richard L. Doernberg
language : en
Publisher: West Publishing Company
Release Date : 2001
International Taxation In A Nutshell written by Richard L. Doernberg and has been published by West Publishing Company this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001 with Business & Economics categories.
After an introduction to the fundamentals of U.S. international taxation, the U.S. activities of foreign taxpayers and the foreign activities of U.S. citizens and residents are addressed. Special U.S. international tax provisions creating incentives and disincentives for certain conducts or forms of business transactions are looked at and the effect of U.S. transfer taxes (estate, gift and generation-skipping tax) on both resident and nonresident aliens is dealt with.
International Taxation
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Author : Joseph Isenbergh
language : en
Publisher: Thomson West
Release Date : 2005
International Taxation written by Joseph Isenbergh and has been published by Thomson West this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Business & Economics categories.
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
Advanced Introduction To International Tax Law
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Author : Reuven S. Avi-Yonah
language : en
Publisher: Edward Elgar Pub
Release Date : 2015-02-27
Advanced Introduction To International Tax Law written by Reuven S. Avi-Yonah and has been published by Edward Elgar Pub this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-02-27 with Law categories.
'Avi-Yonah's Advanced Introduction to International Taxation Law is a compact and accessible guide to the field. In effect, he has given us two books in one. The first is a very useful general guide to the basics of the rules and how they work in practice, with illuminating international comparisons to the often distinctive U.S. rules. The second is a clear and spirited defense of Avi-Yonah's particular views about international tax policy. These do not attract consensus in the field - nor do anyone else's views - but they can help stimulate further thinking about these complicated and important issues.'- Daniel Shaviro, New York University, USAdvanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax.Systems of taxation deviate between jurisdictions and contrasting, income based levies on both individuals and enterprises are implemented depending on the nature or source of income. This dynamic book explores the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as acting as an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.