Basic Rules Of U S Taxation For Inbound Foreign Investment
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Basic Rules Of U S Taxation For Inbound Foreign Investment
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Author :
language : en
Publisher:
Release Date : 1991
Basic Rules Of U S Taxation For Inbound Foreign Investment written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1991 with Aliens categories.
United States International Taxation
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Author : Philip F. Postlewaite
language : en
Publisher:
Release Date : 2022-02
United States International Taxation written by Philip F. Postlewaite and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-02 with categories.
International Applications Of U S Income Tax Law
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Author : Ernest R. Larkins
language : en
Publisher: John Wiley & Sons
Release Date : 2003-11-20
International Applications Of U S Income Tax Law written by Ernest R. Larkins and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-11-20 with Business & Economics categories.
A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!
Practical Guide To U S Taxation Of International Transactions
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Author : Michael S. Schadewald
language : en
Publisher:
Release Date : 2015
Practical Guide To U S Taxation Of International Transactions written by Michael S. Schadewald and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with Business & Economics categories.
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.
U S Taxation Of International Operations
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Author : G. Michael Tilton
language : en
Publisher:
Release Date : 2011
U S Taxation Of International Operations written by G. Michael Tilton and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Corporations, Foreign categories.
Taxation Of Foreign Investment In U S Real Estate
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Author : United States. Department of the Treasury
language : en
Publisher:
Release Date : 1979
Taxation Of Foreign Investment In U S Real Estate written by United States. Department of the Treasury and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1979 with Aliens categories.
U S International Tax Planning And Policy
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Author : Samuel C. Thompson
language : en
Publisher:
Release Date : 2007
U S International Tax Planning And Policy written by Samuel C. Thompson and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Business & Economics categories.
To access the 2010 Supplemental Materials, click here. This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions and addresses such issues as the U.S. taxation of a branch or U.S. subsidiary owned by a foreign corporation. Part III considers outbound transactions and deals with the U.S. taxation of foreign corporations controlled by U.S. persons. This part also addresses the rules regarding transfer pricing between commonly controlled entities, such as a U.S. parent corporation and its foreign subsidiary. Part IV focuses on cross-border mergers and acquisitions. Particular attention is given to the role of Section 367 on cross border reorganizations. The last sections of most chapters briefly discuss the manner in which South Africa, which has recently reformed its international tax system, addresses the issues presented in the chapter. From a tax planning standpoint, the U.S. tax advisor should have a basic understanding of the interface between the U.S. and foreign tax system involved in the transaction, and these discussions illustrate the interface between two sophisticated systems: the U.S. and South Africa.
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
United States Taxation Of Foreign Investment Income
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Author : Peggy B. Musgrave
language : en
Publisher:
Release Date : 1969
United States Taxation Of Foreign Investment Income written by Peggy B. Musgrave and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1969 with Business & Economics categories.
Foreign Investment In The United States
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Author : Marc M. Levey
language : en
Publisher: John Wiley & Sons
Release Date : 1989
Foreign Investment In The United States written by Marc M. Levey and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 1989 with Corporations, Foreign categories.
This guide provides international investors with information about how to secure the transactions, and discusses treaty shopping, corporate capitalization, securities law considerations, investment guidelines, tax consequences, U.S. employment practices and executive compensation.