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Author : Philip F. Postlewaite
Publisher :
ISBN 13 : 9781531011161
Total Pages : pages
Book Rating : 4.0/5 (111 download)
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:
Author : G. Michael Tilton
Publisher :
ISBN 13 :
Total Pages : 293 pages
Book Rating : 4.:/5 (42 download)
Download or read book United States Taxation of International Outbound Transactions and Operations of U.S. Businesses written by G. Michael Tilton and published by . This book was released on 1999 with total page 293 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : James R. Repetti
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403523905
Total Pages : 458 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Ernest R. Larkins
Publisher : John Wiley & Sons
ISBN 13 : 0471482811
Total Pages : 456 pages
Book Rating : 4.4/5 (714 download)
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!
Author : Michael S. Schadewald
Publisher :
ISBN 13 : 9780808040842
Total Pages : 0 pages
Book Rating : 4.0/5 (48 download)
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.
Author : Robert Meldman
Publisher : Springer
ISBN 13 :
Total Pages : 408 pages
Book Rating : 4.F/5 ( download)
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.
Author : AICPA
Publisher : Wiley
ISBN 13 : 9781119696865
Total Pages : 0 pages
Book Rating : 4.6/5 (968 download)
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].
Author : Paul McDaniel
Publisher : Springer
ISBN 13 :
Total Pages : 240 pages
Book Rating : 4.F/5 ( download)
Download or read book Introduction to United States International Taxation written by Paul McDaniel and published by Springer. This book was released on 1998-02-25 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax practitioners outside the United States whose clients have activities in the country generally rely on their U.S. tax advisors for technical advice on the U.S. tax aspects of their clients' transactions. In order to position themselves to evaluate the advice received and to relate it to their own tax systems, however, foreign tax advisors must place the material they receive from their U.S. counterparts within the overall structure of the U.S. international tax system. Introduction to United States International Taxation provides the structural framework within which a U.S. tax problem can be placed. Now in its fourth edition, this reliable resource presents the basic principles and rules of the U.S. international tax system in a concise, manageable form. Without becoming mired in technical detail, The book provides an overview of the principles adopted by the United States in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the United States or abroad. The inclusion of or reference to many key primary source documents enhances the usefulness of Introduction to United States International Taxation. These include: Internal Revenue Code provisions under discussion the more important Treasury Regulations issued interpreting the statutory rules significant administrative announcements of the Internal Revenue Service (Revenue Rulings and Revenue Procedures) illustrative principal cases
Author : Philip F. Postlewaite
Publisher :
ISBN 13 : 9781594607974
Total Pages : 0 pages
Book Rating : 4.6/5 (79 download)
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.
Author : United States. General Accounting Office
Publisher :
ISBN 13 :
Total Pages : 20 pages
Book Rating : 4.:/5 (31 download)
Download or read book International Taxation written by United States. General Accounting Office and published by . This book was released on 1993 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Malik Hill
Publisher :
ISBN 13 :
Total Pages : 206 pages
Book Rating : 4.7/5 (93 download)
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.
Author : Michael Schadewald
Publisher :
ISBN 13 : 9780808058441
Total Pages : 920 pages
Book Rating : 4.0/5 (584 download)
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.
Author : James R. Repetti
Publisher : Aspen Publishing
ISBN 13 : 1543827241
Total Pages : 369 pages
Book Rating : 4.5/5 (438 download)
Download or read book Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 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 international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: 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 U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights 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 U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.
Author : Michael L. Moore
Publisher :
ISBN 13 :
Total Pages : 774 pages
Book Rating : 4.X/5 (2 download)
Download or read book U.S. Tax Aspects of Doing Business Abroad written by Michael L. Moore and published by . This book was released on 1991 with total page 774 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Reuven Shlomo Avi-Yonah
Publisher :
ISBN 13 :
Total Pages : 684 pages
Book Rating : 4.3/5 (511 download)
Download or read book U.S. International Taxation written by Reuven Shlomo Avi-Yonah and published by . This book was released on 2011 with total page 684 pages. Available in PDF, EPUB and Kindle. Book excerpt: Avi-Yonah, Ring and Brauner's U.S. International Taxation, Cases and Materials provides law teachers with an easy-to-use casebook to teach U.S. international taxation. Because of the complexity of the field, the authors focus on the essentials and explore: How U.S. tax law treats foreign investors deriving income from sources within the United States (inbound transactions) How the law treats U.S. taxpayers deriving foreign source income (outbound transactions) How details of the tax law fit into a broader structure Students are encouraged to fit specific issues into a larger context so they can develop an intuition for where problem areas may lie.
Author : William P. Streng
Publisher :
ISBN 13 :
Total Pages : 790 pages
Book Rating : 4.:/5 (89 download)
Download or read book U.S. Taxation-international Transaction (outbound) written by William P. Streng and published by . This book was released on 1991 with total page 790 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Charles H. Gustafson
Publisher : West Academic Publishing
ISBN 13 :
Total Pages : 1290 pages
Book Rating : 4.F/5 ( download)
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:
