United States Taxation Of Foreign Trusts

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United States Taxation Of Foreign Trusts

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Author : Charles Bruce
language : en
Publisher: Springer
Release Date : 2000-03-30

United States Taxation Of Foreign Trusts written by Charles Bruce and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000-03-30 with Business & Economics categories.

Explanation and comments upon the U.S. tax and reporting rules applicable to foreign trusts. Examples of suggested courses of action for common problems are given throughout.

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.

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.

Foreign Trusts And Foreign Estates

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Author :
language : en
Publisher:
Release Date : 1977

Foreign Trusts And Foreign Estates written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1977 with Foreign trusts categories.

United States Taxation Of Foreign Estates Trusts And Beneficiaries

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Author : Michael A. Heimos
language : en
Publisher:
Release Date :

United States Taxation Of Foreign Estates Trusts And Beneficiaries written by Michael A. Heimos and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Income tax categories.

"... gives a survey of the history of trusts, explains in detail the U.S. federal income, estate, and gift taxation of foreign trusts and estates and their grantors and beneficiaries. The Portfolio also provides a secondary discussion of select U.S. state taxation analogues. An entity is subject to U.S. income taxation as a 'foreign trust' or "foreign estate" if it is classified respectively as such under several U.S. tax code sections"--Page iii.

Introduction To United States International Taxation

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Author : Paul R. McDaniel
language : en
Publisher:
Release Date : 2005

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 2005 with Aliens categories.

The 2005 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 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 ten specific aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts and estates, 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; 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 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. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act . 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.

U S Taxation Of Foreign Estates Trusts And Beneficiaries

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Author : Michael A. Heimos
language : en
Publisher:
Release Date :

U S Taxation Of Foreign Estates Trusts And Beneficiaries written by Michael A. Heimos and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Income tax categories.

"... gives a survey of the history of trusts, explains in detail the U.S. federal income, estate, and gift taxation of foreign trusts and estates and their grantors and beneficiaries. The Portfolio also provides a secondary discussion of select U.S. state taxation analogues. An entity is subject to U.S. income taxation as a "foreign trust" or "foreign estate" if it is classified respectively as such under several U.S. tax code sections."

International Taxation Of Trust Income

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Author : Mark Brabazon
language : en
Publisher: Cambridge University Press
Release Date : 2019-05-02

International Taxation Of Trust Income written by Mark Brabazon and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-05-02 with Law categories.

This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

U S Taxation Of Foreign Source Income Of Individuals And Corporations And The Domestic International Sales Corporation Provisions

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Author : United States. Congress. Joint Committee on Internal Revenue Taxation
language : en
Publisher:
Release Date : 1975

U S Taxation Of Foreign Source Income Of Individuals And Corporations And The Domestic International Sales Corporation Provisions written by United States. Congress. Joint Committee on Internal Revenue Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1975 with Income tax categories.

A Guide To U S Taxation Of Foreign Nationals And Americans Abroad

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Author : Robert A. Garber
language : en
Publisher:
Release Date : 1967

A Guide To U S Taxation Of Foreign Nationals And Americans Abroad written by Robert A. Garber and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1967 with Aliens categories.