Elements Of International Income Taxation
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Elements Of International Income Taxation
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Author : Philippe Malherbe
language : en
Publisher: Bruylant
Release Date : 2015-05-26
Elements Of International Income Taxation written by Philippe Malherbe and has been published by Bruylant this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-05-26 with Law categories.
Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented. An appendix includes the juxtalinear texts of the OECD and UN Model Conventions.
International Aspects Of U S Income Taxation Part 4 U S Income Tax Treaties Part 5 Control Of International Tax Evasion
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Author : Elisabeth A. Owens
language : en
Publisher:
Release Date : 1980
International Aspects Of U S Income Taxation Part 4 U S Income Tax Treaties Part 5 Control Of International Tax Evasion written by Elisabeth A. Owens and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1980 with Aliens categories.
Federal Income Tax Project
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Author : American Law Institute
language : en
Publisher:
Release Date : 1992
Federal Income Tax Project written by American Law Institute and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992 with Business & Economics categories.
Proposals on United States income tax treaties. The book is a companion volume to "International aspects of United States income taxation" published in 1987. While the 1987 volume addressed various aspects of US internal income tax law as applied to international transactions, this volume deals with the special set of problems involved in treaties between the US and their trading partners by which it is sought to bring divergent national tax laws and incidents of taxation into reasonable accord.
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
International Aspects Of U S Income Taxation
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Author : Elisabeth A. Owens
language : en
Publisher:
Release Date : 1980
International Aspects Of U S Income Taxation written by Elisabeth A. Owens and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1980 with Business & Economics categories.
Casebook divided into five subtopics dealing with international tax aspects under US tax law.
International Taxation U S Taxation Of Foreign Persons And Foreign Income
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Author : J. Isenbergh
language : en
Publisher:
Release Date : 2000
International Taxation U S Taxation Of Foreign Persons And Foreign Income written by J. Isenbergh and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000 with categories.
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.
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.
International Income Taxation
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Author : Robert J. Peroni
language : en
Publisher: CCH
Release Date : 2008
International Income Taxation written by Robert J. Peroni and has been published by CCH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Corporations, Foreign categories.
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.
International Aspects Of U S Income Taxation
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Author : John P. Steines, Jr.
language : en
Publisher:
Release Date : 2014
International Aspects Of U S Income Taxation written by John P. Steines, Jr. and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with categories.
International Aspects Of The Us Taxation System
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Author : Felix I. Lessambo
language : en
Publisher: Springer
Release Date : 2016-09-29
International Aspects Of The Us Taxation System written by Felix I. Lessambo and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-09-29 with Business & Economics categories.
This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.