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Elements Of International Income Taxation
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Book Synopsis Elements of International Income Taxation by : Philippe Malherbe
Download or read book Elements of International Income Taxation written by Philippe Malherbe and published by Bruylant. This book was released on 2015-05-26 with total page 145 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis International Income Taxation by : Robert J. Peroni
Download or read book International Income Taxation written by Robert J. Peroni and published by CCH. This book was released on 2008 with total page 2356 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Tax Law Design and Drafting, Volume 1 by : Mr.Victor Thuronyi
Download or read book Tax Law Design and Drafting, Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
Book Synopsis Federal Income Tax Project by : American Law Institute
Download or read book Federal Income Tax Project written by American Law Institute and published by . This book was released on 1992 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Introduction to United States International Taxation by : James R. Repetti
Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis International Law of Taxation by : Peter Hongler
Download or read book International Law of Taxation written by Peter Hongler and published by Oxford University Press. This book was released on 2021 with total page 289 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.
Book Synopsis Federal Income Tax Project by : American Law Institute
Download or read book Federal Income Tax Project written by American Law Institute and published by . This book was released on 1987 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proposals on United States taxation of foreign persons and of the foreign income of United States persons.
Book Synopsis International Taxation : U.S. Taxation of Foreign Persons and Foreign Income by : J. Isenbergh
Download or read book International Taxation : U.S. Taxation of Foreign Persons and Foreign Income written by J. Isenbergh and published by . This book was released on 2000 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis International Aspects of the US Taxation System by : Felix I. Lessambo
Download or read book International Aspects of the US Taxation System written by Felix I. Lessambo and published by Springer. This book was released on 2016-09-29 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis International Taxation by : Joseph Isenbergh
Download or read book International Taxation written by Joseph Isenbergh and published by Thomson West. This book was released on 2005 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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
Book Synopsis International Aspects of U.S. Income Taxation by : John P. Steines, Jr.
Download or read book International Aspects of U.S. Income Taxation written by John P. Steines, Jr. and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Income Taxation by : Robert J. Peroni
Download or read book International Income Taxation written by Robert J. Peroni and published by CCH Incorporated. This book was released on 2016-07-16 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2014-2015 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
Book Synopsis Introduction to United States International Taxation by : Paul R. McDaniel
Download or read book Introduction to United States International Taxation written by Paul R. McDaniel and published by . This book was released on 2005 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Federal Income Tax Project written by and published by . This book was released on 1992 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Income Taxation by : Robert J. Peroni
Download or read book International Income Taxation written by Robert J. Peroni and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2016-2017 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. In this comprehensive and easy-to-use volume, Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country. Code and Regulations sections included are those deemed to be essential to International Tax teachers, students and practitioners.The 2016-2017 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2016. ABOUT THE EDITORS:This authoritative volume is edited by a team of highly regarded professors:- Robert J. Peroni, Coordinating Editor--Parker C. Fielder Regents Professor of Law, University of Texas- Richard C. Pugh, Contributing Editor--Distinguished Professor of Law, University of San Diego- Charles H. Gustafson, Contributing Editor--Professor of Law, Georgetown University
Book Synopsis International Income Taxation by : Robert J. Peroni
Download or read book International Income Taxation written by Robert J. Peroni and published by . This book was released on 2013-07-15 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2013-2014 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. Includes CD of entire contents of book. In this comprehensive and easy-to-use volume, Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country. Code and Regulations sections included are those deemed to be essential to International Tax teachers, students and practitioners. The 2013-2014 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2013.
Book Synopsis International Income Taxation: Code and Regulationsselected Sections (20142015 Edition) by : Robert J. Peroni
Download or read book International Income Taxation: Code and Regulationsselected Sections (20142015 Edition) written by Robert J. Peroni and published by . This book was released on 2014-07-07 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 20142015 edition of INTERNATIONAL INCOME TAXATION: Code and RegulationsSelected 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 RegulationsSelected 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 multivolume Internal Revenue Code and Income Tax Regulations, this singlevolume reference travels well between home and office and between classroom and dorm. The book features a readerfriendly large 71/4" x 10" format with new larger type fonts for enhanced readability. Includes CD of entire contents of book. In this comprehensive and easytouse volume, Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country. Code and Regulations sections included are those deemed to be essential to International Tax teachers, students and practitioners. The 20142015 edition of INTERNATIONAL INCOME TAXATION: Code and RegulationsSelected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2014. ABOUT THE EDITORS: This authoritative volume is edited by a team of highly regarded professors: Robert J. Peroni, Coordinating EditorParker C. Fielder Regents Professor of Law, University of Texas Richard C. Pugh, Contributing EditorDistinguished Professor of Law, U
