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Inbound And Outbound Taxation In The Us
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Book Synopsis Inbound and Outbound Taxation in the US by : Malik Hill
Download or read book Inbound and Outbound Taxation in the US written by Malik Hill and published by . This book was released on 2021-02-14 with total page 206 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author will do an overview of both outbound taxation and inbound taxation in this monograph. International taxation is a bit of a misleading name because the author is not really talking about how Germany or China or any other country taxes a business transaction, he is not talking solely about how the United States taxes a business transaction, but the writer is talking how the United States taxes a business transaction or really any sort of a transaction that crosses borders, a transaction that is international in flavor.
Book Synopsis United States International Taxation by : Philip F. Postlewaite
Download or read book United States International Taxation written by Philip F. Postlewaite and published by . This book was released on 2022-02 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Applications of U.S. Income Tax Law by : Ernest R. Larkins
Download or read book International Applications of U.S. Income Tax Law written by Ernest R. Larkins and published by John Wiley & Sons. This book was released on 2003-11-20 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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!
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 Palgrave Macmillan. This book was released on 2016-09-29 with total page 0 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 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 389 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 : Philip F. Postlewaite
Download or read book International Taxation written by Philip F. Postlewaite and published by . This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.
Book Synopsis Structuring Cross-Border Transactions by : Mindy Herzfeld
Download or read book Structuring Cross-Border Transactions written by Mindy Herzfeld and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
Book Synopsis Practical Guide to U.S. Taxation of International Transactions by : Michael S. Schadewald
Download or read book Practical Guide to U.S. Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Basic Rules of U.S. Taxation for Inbound Foreign Investment by :
Download or read book Basic Rules of U.S. Taxation for Inbound Foreign Investment written by and published by . This book was released on 1991 with total page 386 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis A Practical Guide to U. S. Taxation of International Transactions by : Robert Meldman
Download or read book A Practical Guide to U. S. Taxation of International Transactions written by Robert Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign 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 U.S. International Tax Planning and Policy by : Samuel C. Thompson
Download or read book U.S. International Tax Planning and Policy written by Samuel C. Thompson and published by . This book was released on 2016 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: To view or download the 2018 Supplement to this book, click here. This book addresses the federal income tax treatment of (1) foreign individuals and corporations in the U.S. (i.e., inbound transactions), and (2) U.S. individuals and corporations abroad (i.e., outbound transactions). After considering basic principles and treaties in Part I, Part II deals with inbound transactions; Part III addresses outbound transactions; and Part IV focuses on cross-border mergers and acquisitions. In many chapters the book compares the U.S. approach with the approach taken under the income tax law of South Africa, which has an income tax treaty with the U.S.
Download or read book U.S. International Tax written by AICPA and published by Wiley. This book was released on 2020-03-31 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The U.S. International Tax: Core Concepts (9.0 CPE Credits) covers topics such as distinguishing the differences between various types of global tax systems and certain characteristics of each, entity classifications and different forms of operating a business in a foreign country. Valuable to anyone who needs to understand the complexities of international taxation, this U.S. International Tax: Core Concepts bundle offers you the opportunity to build a solid foundation in U.S. international taxation. The two-part series of self-study online courses is part of the U.S. International Tax Certificate, a comprehensive learning program developed in partnership with Grant Thornton geared to help global finance and accounting professionals navigate the highly complex world of international taxation. The series includes: International Tax Foundation Introduction to U.S. Outbound and Inbound Transactions WHO WILL BENEFIT? Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation KEY TOPICS Tax Systems Inbound/Outbound Taxation Residency Foreign Tax Credits Entity Classification Subpart F Income Taxable presence in U.S. Income Sourcing in U.S. Withholding taxes in U.S. Tax Treaties Transfer pricing Key Actions under OECD BEPS initiative FDII GILTI LEARNING OBJECTIVES Part 1: Distinguish the differences between various types of global tax systems and certain characteristics of each Recall how the U.S. tax system works Recall entity classification and hybrids Recognize the different forms of operating a business in a foreign country Recall the concept of a permanent establishment / taxable presence in the United States and globally Recall U.S. income sourcing rules Identify general U.S. withholding tax rules Recognize the general function and benefits of most income tax treaties Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative Part 2: Identify business transactions that generate outbound tax issues. Recognize the approach for taxing U.S. persons with foreign activities. Describe the key tax reform provisions affecting outbound transactions. Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations. Recognize foreign currency issues affecting outbound transactions. Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships. Recall effectively connected income (ECI) to a U.S. trade or business Recall the rules for sourcing of income Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP) Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT) Indicate a general framework on the U.S. withholding taxes Digital Badge: Your Professional Distinction Set yourself apart as a future-ready financial professional. Upon completion, you will be awarded with a certificate in the form of a digital badge. Digital badges allow you to distinguish yourself in the marketplace and show your commitment to quality. The badge can be posted to your social media profiles and linked to your resume or email signature, providing maximum visibility to your achievement. Credit Info CPE CREDITS: Online: 9.0 (CPE credit info) NASBA FIELD OF STUDY: Taxes LEVEL: Basic PREREQUISITES: None ADVANCE PREPARATION: None DELIVERY METHOD: QAS Self-Study COURSE ACRONYM: ITC_181_1 Online Access Instructions A personal pin code is enclosed in the physical packaging that may be activated online upon receipt. Once activated, you will gain immediate online access to the product for one full year. System Requirements AICPA’s online CPE courses will operate in a variety of configurations, but only the configuration described below is supported by AICPA technicians. A stable and continuous internet connection is required. In order to record your completion of the online learning courses, please ensure you are connected to the internet at all times while taking the course. It is your responsibility to validate that CPE certificate(s) are available within your account after successfully completing the course and/or exam. Supported Operating Systems: Macintosh OS X 10.10 to present Windows 7 to present Supported Browsers: Apple Safari Google Chrome Microsoft Internet Explorer Mozilla Firefox Required Browser Plug-ins: Adobe Flash Adobe Acrobat Reader Technical Support: Please contact [email protected].
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 Taxation: U.S. Taxation of Foreign Persons and Foreign Income (2022) by : Joseph Isenbergh
Download or read book International Taxation: U.S. Taxation of Foreign Persons and Foreign Income (2022) written by Joseph Isenbergh and published by . This book was released on 2021-12-30 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation is a comprehensive treatise written by Joseph Isenbergh, Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners.
Book Synopsis International Taxation by : JOSEPH. WELLS ISENBERGH (BRET.)
Download or read book International Taxation written by JOSEPH. WELLS ISENBERGH (BRET.) and published by Foundation Press. This book was released on 2019-12-10 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Fourth Edition is divided into three sections: common elements of international taxation for both inbound and outbound taxation, inbound U.S. taxation, and outbound U.S. taxation. Special attention is focused on base erosion and profit shifting strategies and the resulting complexity that has been added to the U.S. tax regime to address this phenomenon in the inbound and outbound context. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.
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:
