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Taxation Of Transnational Transactions
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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 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 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 2001 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Taxation of Transnational Transactions by :
Download or read book Taxation of Transnational Transactions written by and published by . This book was released on 1990 with total page 1554 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Taxation of Banking by : John Abrahamson
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Book Synopsis A Practical Guide to U.S. Taxation of International Transactions by : Robert E. Meldman
Download or read book A Practical Guide to U.S. Taxation of International Transactions written by Robert E. Meldman and published by Springer. This book was released on 2000-06-22 with total page 516 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses basis principles (tax jurisdiction, source of income rules), U.S. taxation of foreign income (foreign tax credit, transfer pricing, anti-avoidance provisions governing foreign corporations, foreign sales corporations, foreign currency translation and transactions, tax treaties, planning of foreign operations) and U.S. taxation of foreign persons (foreign persons investing in the U.S. and foreign persons doing business in the U.S.).
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 . This book was released on 1995 with total page 860 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of International Business Transactions by : Felix I. Lessambo
Download or read book Taxation of International Business Transactions written by Felix I. Lessambo and published by iUniverse. This book was released on 2009 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With the increase in global trade now and in the future and the growth of multinational companies, an understanding of international tax law is imperative. In Taxation of International Business Transactions, author Dr. Felix Lessambo provides an overview of the sometimes challenging international tax law. Taxation of International Business Transactions provides sound understanding of foreign tax regimes and more. It is geared for those who want to mitigate, increase, and avoid tax audits in the areas of thin-capitalization, employee-secondment, transfer pricing, and limitations-on-benefits (LOB). Lessambo has tracked the ongoing issues of the most relevant aspects of international taxations and delivers suggestions in this edition. Lessambo, an international tax scholar and practitioner recognized for his keen analyses, provides firsthand expertise to help multinationals and international business managers to pursue business initiatives without the fear of unintended tax consequences. Taxation of International Business Transactions is an indispensable guide for tax and financial directors and those dealing with tax at a worldwide level."--Publisher's website.
Book Synopsis Practical Guide to U.S. Taxation of International Transactions (13th) by : Michael Schadewald
Download or read book Practical Guide to U.S. Taxation of International Transactions (13th) written by Michael Schadewald and published by . This book was released on 2022-08-14 with total page 920 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 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 Taxation of International Transactions by : ROBERT J.. BROWN PERONI (KAREN B.. FLEMING, J. CLIFTON.)
Download or read book Taxation of International Transactions written by ROBERT J.. BROWN PERONI (KAREN B.. FLEMING, J. CLIFTON.) and published by West Academic Publishing. This book was released on 2021-07-06 with total page 1212 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools, and schools of management, this significantly revised casebook (formerly Gustafson, Peroni, and Pugh's Taxation of International Transactions) outlines the determination of U.S. income tax liabilities resulting from international transactions and the issues attending administration of the U.S. international tax rules. Textual discussion, cases, rulings, and problems guide students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, as well as those confronting U.S. individuals and entities seeking to derive income abroad. It covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules. This book fully covers all the significant provisions of the Tax Cuts and Jobs Act of 2017 and subsequent regulatory and administrative guidance regarding those provisions, including the revised foreign tax credit limitations, the participation exemption system in Section 245A, and the GILTI and FDII provisions.
Download or read book The Study of Federal Tax Law written by and published by . This book was released on 1983 with total page 1174 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Practical Guide to U. S. Taxation of International Transactions by : Robert J. Misey
Download or read book Practical Guide to U. S. Taxation of International Transactions written by Robert J. Misey and published by . This book was released on 2007-09-01 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transnational Legal Orders by : Terence C. Halliday
Download or read book Transnational Legal Orders written by Terence C. Halliday and published by Cambridge University Press. This book was released on 2015-01-19 with total page 559 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transnational Legal Orders offers an empirically grounded approach to the emergence of legal orders beyond nation-states that reframes the study of law and society.
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 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book 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. 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.
Book Synopsis Beneficial Ownership in International Tax Law by : Angelika Meindl-Ringler
Download or read book Beneficial Ownership in International Tax Law written by Angelika Meindl-Ringler and published by Kluwer Law International B.V.. This book was released on 2016-06-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
