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International Tax Planning For United States Based Business
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Book Synopsis International Company Taxation and Tax Planning by : Dieter Endres
Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.
Book Synopsis International Tax Planning for United States Based Business by : Norman
Download or read book International Tax Planning for United States Based Business written by Norman and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis U.S. Tax Treaties by : United States. Internal Revenue Service
Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income by : Christoph Spengel
Download or read book Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income written by Christoph Spengel and published by Springer Science & Business Media. This book was released on 2012-03-13 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt: The study conducted by the Centre of European Economic Research (ZEW), the University of Mannheim and Ernst & Young contributes to the ongoing evaluation of the proposal for a Draft Council Directive on a Common Consolidated Corporate Tax Base (CC(C)TB) released by the European Commission on March 16, 2011. For the first time, details on the determination of taxable income under the proposed Council Directive are compared to prevailing corporate tax accounting regulations in all 27 Member States, Switzerland and the US. The study presents evidence on the scope of differences and similarities between national tax accounting regulations and the Directive’s treatment in a complete, yet concise form. Based on this comprehensive comparison, it goes on to discuss remaining open questions and adjustments needed if the Directive is to be implemented in national tax law. Readers seeking a basis for taking an active part in the public debate will find a valuable source of information and a first impression of how the proposed CC(C)TB would affect corporate tax burdens in the European Union.
Book Synopsis International Taxation in America for the Entrepreneur by : Brian Dooley
Download or read book International Taxation in America for the Entrepreneur written by Brian Dooley and published by CreateSpace. This book was released on 2014-03-20 with total page 134 pages. Available in PDF, EPUB and Kindle. Book excerpt: When you are reading "International Taxation in America for the Entrepreneur," you'll learn to redefine your meaning of the word "Taxation" ...that elusive "something" that is an inherent problem in so many of your businesses...and you'll gain the insight of how to move beyond the myths and the barriers that can cause your "bottom line" to be adversely affected. Today's entrepreneurs are finding cross border business planning is easier than ever before. The cross border business and the multinational family are using offshore "foreign trusts" for tax planning, inheritance planning and asset protection. "International Taxation in America for the Entrepreneur" is explains the tried and true international tax plans of successful businesses. It is designed for the busy business owner. The book has the blueprints of the best foreign tax structures. Besides international tax planning articles, tax treaties, rulings, regulations and leading court cases, you have access to our Custom Google site that includes more than 300,000 hidden pages on the IRS web site and our blog. Brian Dooley, CPA, MBT has been specializing in offshore taxation since 1980. He has helped numerous accountants and attorneys serve a broad range of individual and business clients in various international tax and estate planning matters. Also, he has on nine occasions offered expert witness testimony before the U.S. Department of Treasury and the U.S. House of Representatives on issues related to foreign investments, foreign trusts and private annuities. Mr. Dooley is the founder of International Tax Counselors. His firm brings together a team of attorneys and certified public accountants. With a passion for perfection, the firm assist foreign individuals investing in the United States and Americans with their foreign businesses. Brian Dooley can be contacted at [email protected]. He specializes in assisting other CPA's and law firms with their clients international tax issues. You can learn more about his services at www.IntlTaxCounselors.com. His experience includes: * Obtaining private letter rulings and voluntary disclosure agreements from the IRS * Resolving (on an anonymous basis) undisclosed cross-border tax issues with the IRS * Advising attorneys and CPA's, since 1976, on 100's of international tax audits and IRS agreements, * Developing tax-efficient international estate plans * Implementing strategies that minimize cross-border taxes Expertise Brian's forte is obtaining written IRS rulings on tax planning strategies to guarantee savings. He also excels in counseling chartered accountants, CPAs and attorneys in international tax law. He is highly skilled in using the IRS tax-amnesty program, private letter rulings, foreign business tax credits and offshore trusts to help clients: * Achieve their international tax and estate planning objectives * Protect themselves from audits, penalties and unpleasant tax surprises * Avoid IRS tax controversy * Set up captive insurance companies * Deal with foreign inheritances * Immigrate into the United States or open a U.S. office for a foreign company Publications * Estate Planning with a Foreign Trust * Contributing author to Taxation of International Transactions, edited by Matthew Bender Involvements * American Institute of Certified Public Accountants, Member * California Society of Certified Public Accountants, Member Education B.S. in Accounting and Masters in Business Taxation from the University of Southern California.
Book Synopsis Tax Planning for Foreign Investors in the United States by : Adam Starchild
Download or read book Tax Planning for Foreign Investors in the United States written by Adam Starchild and published by Springer Science & Business Media. This book was released on 2013-06-29 with total page 154 pages. Available in PDF, EPUB and Kindle. Book excerpt: If you arenot a citizen or resident of the United States (U.S.) and you are contemplating either making or expanding an investment in the U .S., either for yourself as an individual or for a business, you arenot alone. The U.S. is the country of first choice for many foreign investors. This is due to the fact that the U.S. offers foreign investors many advantages, some ofwhich are in short supply in today's world. The primary advantage that the U.S. affords foreign investorsisthat it endorses the economic concept of free enterprise. While it is true that the Federal and state governments have interfered with the private economy to some extent, the prevailing economic philosophy in the U .S. remains laissez faire. History has taught the U.S. that the market place allocates the finite resources of a country betterthan the government, and the advantagesoftbis philosophy have not been overlooked by foreign investors. Another attractive feature of the U .S. as an investment site is its political stability. The present form of constitutional government has presided for over 200 years, and this history provides foreign investors with a measure of security which is absent elsewhere.
Book Synopsis International Taxation by : Adnan Islam
Download or read book International Taxation written by Adnan Islam and published by John Wiley & Sons. This book was released on 2020-09-01 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction. Information is provided for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017, this guide covers international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the United States. Key topics include: Export income Receipts in foreign currency Allocation and apportionment of deductions U.S. foreign tax credit fundamentals and special rules Initiation of foreign operations Foreign branches and affiliated companies Sale of use of tangible property Foreign business operations in the United States Foreign business sales of tangible property in the United States Foreign business provision of services in the United States Exploitation of business assets outside of the United States Use of foreign tangible/intangible property in the United States U.S. withholding taxes on foreign businesses FDII GILTI
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 U.S. Investment Since the Tax Cuts and Jobs Act of 2017 by : Emanuel Kopp
Download or read book U.S. Investment Since the Tax Cuts and Jobs Act of 2017 written by Emanuel Kopp and published by International Monetary Fund. This book was released on 2019-05-31 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
Book Synopsis International Tax Planning by : William C. Gifford
Download or read book International Tax Planning written by William C. Gifford and published by . This book was released on 1979 with total page 760 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis United States Inbound Business Tax Planning by : Bernard Moens
Download or read book United States Inbound Business Tax Planning written by Bernard Moens and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... is a practical planning guide for structuring foreign investment into the United States. It presents a cross-disciplinary approach based on the experience of practitioners in the areas of U.S. international tax, transfer pricing, and state and local tax. The portfolio addresses topics that are most relevant to foreign-based multinational corporations doing business in the United States. They include a framework of U.S. inbound income taxation, state tax, formation of a U.S. business, financing U.S. operations, ownership of intangible property, and inbound acquisitions and restructurings.
Book Synopsis The International Taxation System by : Andrew Lymer
Download or read book The International Taxation System written by Andrew Lymer and published by Springer Science & Business Media. This book was released on 2002-08-31 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Book Synopsis The Netherlands in International Tax Planning by : Johann Müller (podatki)
Download or read book The Netherlands in International Tax Planning written by Johann Müller (podatki) and published by IBFD. This book was released on 2007 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.
Book Synopsis Tax Planning for U.S. MNCs with EU Holding Companies by : Pia Dorfmueller
Download or read book Tax Planning for U.S. MNCs with EU Holding Companies written by Pia Dorfmueller and published by . This book was released on 2003 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax planning for U.S. companies doing business in the EU. Analyses the design of tax conversion and deferral structures that are advantageous to U.S. multinationals to reach their goals: minimizing liability, maximizing credits, deducting expenses, and utilizing losses; using tools such as routing of income and classification of entities; and overcoming barriers like the CFC provisions of the U.S. tax law. Examines U.S. federal corporate law and analyses European company taxation, with specific tax planning techniques for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg, and Switzerland.
Book Synopsis International Tax Planning and Prevention of Abuse by : Luc De Broe
Download or read book International Tax Planning and Prevention of Abuse written by Luc De Broe and published by IBFD. This book was released on 2008 with total page 1146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Book Synopsis Studies in International Taxation by : Alberto Giovannini
Download or read book Studies in International Taxation written by Alberto Giovannini and published by University of Chicago Press. This book was released on 2007-12-01 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies. The contributors to this volume are Rosanne Altshuler, Alan J. Auerbach, Neil Bruce, Timothy Goodspeed, Roger H. Gordon, Harry Grubert, Bronwyn H. Hall, David Harris, Kevin Hassett, James R. Hines Jr., Roy D. Hogg, Joosung Jun, Jeffrey K. Mackie-Mason, Jack M. Mintz, Randall Morck, John Mutti, T. Scott Newlon, James M. Poterba, Joel Slemrod, Deborah Swenson, G. Peter Wilson, and Bernard Yeung.
Book Synopsis U.S. International Taxation by : Joel D. Kuntz
Download or read book U.S. International Taxation written by Joel D. Kuntz and published by . This book was released on 1991 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
