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Controlled Foreign Companies Foreign Personal Holding Company Income
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Book Synopsis Controlled Foreign Companies--Foreign Personal Holding Company Income by : Lowell D. Yoder
Download or read book Controlled Foreign Companies--Foreign Personal Holding Company Income written by Lowell D. Yoder and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... provides a detailed analysis of one of the categories of foreign base company income: foreign personal holding company income, which includes certain dividends, interest, related person factoring income, rents, royalties, income from annuities, commodities transactions, and foreign currency transactions, and certain other income."--Page iii.
Book Synopsis CFCs--Foreign Base Company Income (other Than FPHCI) by : Lowell D. Yoder
Download or read book CFCs--Foreign Base Company Income (other Than FPHCI) written by Lowell D. Yoder and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...provides a detailed analysis of two of the three categories of foreign base company income: foreign base company sales income and foreign base company services income. It also analyzes foreign base company shipping income, which was a category of foreign base company income until its repeal by the American Jobs Creation Act of 2004, and foreign base company oil related income, which was a category of foreign base company income until its repeal by "An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018." The exceptions to these categories and special rules relating thereto are also discussed in detail, including the de minimis rule, full-inclusion rule, and high-tax exception. Moreover, the application of the foreign base company income rules to partnerships with CFC partners is analyzed. The third category of foreign base company income is foreign personal holding company income (including dividends, interest, related-person factoring income, rents, royalties, annuities, commodities gains, foreign currency gains, and other income). This category of foreign base company income is discussed and analyzed in relation to the other categories of foreign base company income. Foreign personal holding company income is analyzed in detail in 6220 T.M., CFCs -- Foreign Personal Holding Company Income."
Book Synopsis Controlled Foreign Company Legislation by : Organisation for Economic Co-operation and Development
Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Book Synopsis Description and Analysis of Present-law Tax Rules Relating to Income Earned by U.S. Businesses from Foreign Operations by :
Download or read book Description and Analysis of Present-law Tax Rules Relating to Income Earned by U.S. Businesses from Foreign Operations written by and published by . This book was released on 1995 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Controlled Foreign Companies by : Lee Burns
Download or read book Controlled Foreign Companies written by Lee Burns and published by . This book was released on 1992 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is an explanation of Australia's CFC rules. It places the legislation in context, provides a framework for analysing problems and describes the new regime in detail.
Book Synopsis Proposal Relating to Current U.S. Taxation of Certain Operations of Controlled Foreign Corporations (H.R. 2889--American Jobs and Manufacturing Preservation Act of 1991) and Related Issues by : United States. Congress. House. Committee on Ways and Means
Download or read book Proposal Relating to Current U.S. Taxation of Certain Operations of Controlled Foreign Corporations (H.R. 2889--American Jobs and Manufacturing Preservation Act of 1991) and Related Issues written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1991 with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Taxation of Controlled Foreign Corporations by : John Prebble
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Book Synopsis A Summary of Administration Recommendations on U.S. Taxation of Foreign Income and Foreign Persons by : United States. Congress. Senate. Committee on Finance
Download or read book A Summary of Administration Recommendations on U.S. Taxation of Foreign Income and Foreign Persons written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 1974 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis U.S. Corporations Doing Business Abroad by :
Download or read book U.S. Corporations Doing Business Abroad written by and published by . This book was released on 1985 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxing Offshore Investment Income by : John Prebble
Download or read book Taxing Offshore Investment Income written by John Prebble and published by . This book was released on 2006 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: An international panel of experts address the design and operation of offshore investment fund regimes. The book is comparative, dealing with topics issue-by-issue rather than country-by-country. (Legal Reference/Law)
Book Synopsis Taxation of International Transactions by : Charles H. Gustafson
Download or read book Taxation of International Transactions written by Charles H. Gustafson and published by West Academic Publishing. This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Book Synopsis CFCs--investment of Earnings in United States Property by : Philip Fried (Lawyer)
Download or read book CFCs--investment of Earnings in United States Property written by Philip Fried (Lawyer) and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investments of earnings and profits by controlled foreign corporations in United States property. This Portfolio discusses the circumstances under which such investments may result in the taxation to the company's U.S. shareholders of a portion of the company's earnings and profits, and it explains the rules governing the computation of such income inclusion. It describes the possibility of unexpected results from the operation of the §956 rules, and it suggests planning possibilities to avoid pitfalls. Among the matters discussed are the definition of the term "United States property" and the exceptions thereto; calculations of the amount of a controlled foreign corporation's earnings and profits invested in United States property and the effect of distributions on such calculations; special rules regarding the taxation of U.S. shareholders, including the applicable foreign tax credit rules; and tax planning opportunities."
Book Synopsis CFCs--Foreign Personal Holding Company Income by : Lowell D. Yoder
Download or read book CFCs--Foreign Personal Holding Company Income written by Lowell D. Yoder and published by . This book was released on 2004 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis General Explanation of the Tax Reform Act of 1986 by :
Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1412 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Operating Abroad Under Current U.S. Tax Rules and Economic Policies by : Practising Law Institute
Download or read book Operating Abroad Under Current U.S. Tax Rules and Economic Policies written by Practising Law Institute and published by . This book was released on 1965 with total page 200 pages. Available in PDF, EPUB and Kindle. Book excerpt:
