United States Taxation Of International Shipping And Air Transport Activities

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United States Taxation of International Shipping and Air Transport Activities

Author : Peter A. Glicklich
Publisher :
ISBN 13 : 9781633590304
Total Pages : pages
Book Rating : 4.5/5 (93 download)

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Book Synopsis United States Taxation of International Shipping and Air Transport Activities by : Peter A. Glicklich

Download or read book United States Taxation of International Shipping and Air Transport Activities written by Peter A. Glicklich and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...discusses the three tax regimes to which nonresident alien individuals and foreign corporations that conduct shipping or air transport activities within the United States may be subject: (1) the general provisions of the Internal Revenue Code of 1986, as amended, for foreign persons with certain modifications; (2) a "reciprocal exemption" provided by [section] 872(b) and [section] 883; or (3) the similar, but separate, exemption available under many U.S. income tax treaties. This Portfolio sets forth in detail the U.S. tax rules applicable under each of the three tax regimes, including in particular the requirements that must be satisfied to qualify for an exemption under either [section] 872(b) and [section] 883 or an applicable U.S. income tax treaty. In this regard, particular emphasis is given to Treasury Regulations issued in 2003 that make it substantially more burdensome for foreign corporations to claim the reciprocal exemption provided by [section] 872(b) and [section] 883."

Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties

Author : Guglielmo Maisto
Publisher :
ISBN 13 : 9789087224035
Total Pages : 698 pages
Book Rating : 4.2/5 (24 download)

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Book Synopsis Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties by : Guglielmo Maisto

Download or read book Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties written by Guglielmo Maisto and published by . This book was released on 2017 with total page 698 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book comprising the proceedings and working documents of an annual seminar held in Milan in November 2016, is a detailed and comprehensive study on the taxation of highly transnational industries engaged in the shipping and air transport sectors. It begins with a comparative analysis of the domestic regulatory and tax regimes of such industries and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union on tonnage taxation systems and VAT regimes. The book then moves to selected tax treaty issues. In particular, it analyses: (i) the historical background and the proposed changes to articles 8 and 15(3) of the OECD Model Convention; (ii) the recent developments concerning article 8 of the OECD Model Convention and the application of the place of effective management criterion, instead of the residence criterion, as connecting factor; (iii) the most relevant tax treaty issues related to the qualification, allocation and apportionment of income derived by shipping and air transport activities; and (iv) the taxation of the remuneration of crews of ships and aircraft. Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices of various states, including Australia, Austria, Brazil, Canada, China and Hong Kong, Denmark, Germany, Greece, Italy, Liberia, the Netherlands, Spain, Switzerland and the United Kingdom.

Introduction to United States International Taxation

Author : James R. Repetti
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403523905
Total Pages : 458 pages
Book Rating : 4.4/5 (35 download)

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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.

A Practical Guide to U. S. Taxation of International Transactions

Author : Robert Meldman
Publisher : Springer
ISBN 13 :
Total Pages : 408 pages
Book Rating : 4.F/5 ( download)

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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.

United States International Taxation

Author : Philip F. Postlewaite
Publisher :
ISBN 13 : 9781531011161
Total Pages : pages
Book Rating : 4.0/5 (111 download)

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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:

Introduction to United States International Taxation

Author : Paul McDaniel
Publisher : Springer
ISBN 13 :
Total Pages : 240 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Introduction to United States International Taxation by : Paul McDaniel

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

International Taxation of Energy Production and Distribution

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041191208
Total Pages : 546 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Taxation of Energy Production and Distribution by : John Abrahamson

Download or read book International Taxation of Energy Production and Distribution written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2018-04-20 with total page 546 pages. Available in PDF, EPUB and Kindle. Book excerpt: Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries. The book introduces and analyses significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. The taxation issues covered include the following: – upstream oil and gas and mining taxes; – incentives for renewable energy; – carbon taxes and emission trading regimes; – dividend, interest, and royalty flows; – foreign tax credits; – permanent establishments; – mergers and acquisitions; – taxation issues for derivatives and hedging; – transfer pricing; – regional purchasing, marketing, service, and intangible property structures; – free trade agreements and customs unions; – dispute resolution; and – tax administration and risk management. Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples, and gain practice in identifying and discussing relevant international taxation issues. This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.

Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Kingdom of Spain

Author : United States. Congress. Joint Committee on Taxation
Publisher :
ISBN 13 :
Total Pages : 68 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Kingdom of Spain by : United States. Congress. Joint Committee on Taxation

Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Kingdom of Spain written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1990 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Explanation of Proposed Income Tax Treaty Between the United States and Japan

Author :
Publisher :
ISBN 13 :
Total Pages : 128 pages
Book Rating : 4.:/5 (327 download)

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Book Synopsis Explanation of Proposed Income Tax Treaty Between the United States and Japan by :

Download or read book Explanation of Proposed Income Tax Treaty Between the United States and Japan written by and published by . This book was released on 2004 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States of America and the Republic of India

Author :
Publisher :
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States of America and the Republic of India by :

Download or read book Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States of America and the Republic of India written by and published by . This book was released on 1990 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Exploring the Nexus Doctrine In International Tax Law

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403533641
Total Pages : 234 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh

Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.

Practical Guide to U.S. Taxation of International Transactions

Author : Michael S. Schadewald
Publisher :
ISBN 13 : 9780808040842
Total Pages : 0 pages
Book Rating : 4.0/5 (48 download)

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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.

America's Container Ports

Author : U.s. Department of Transportation
Publisher : Createspace Independent Publishing Platform
ISBN 13 : 9781723462894
Total Pages : 52 pages
Book Rating : 4.4/5 (628 download)

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Book Synopsis America's Container Ports by : U.s. Department of Transportation

Download or read book America's Container Ports written by U.s. Department of Transportation and published by Createspace Independent Publishing Platform. This book was released on 2018-07-23 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt: America's container ports : linking markets at home and abroad.

International Co-operation in Tax Matters

Author : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters
Publisher : New York : Department of International Economic and Social Affairs, United Nations
ISBN 13 :
Total Pages : 152 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis International Co-operation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters

Download or read book International Co-operation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by New York : Department of International Economic and Social Affairs, United Nations. This book was released on 1987 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt:

U.S. Income Tax Treaties

Author : Richard L. Doernberg
Publisher :
ISBN 13 :
Total Pages : 444 pages
Book Rating : 4.:/5 (327 download)

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Book Synopsis U.S. Income Tax Treaties by : Richard L. Doernberg

Download or read book U.S. Income Tax Treaties written by Richard L. Doernberg and published by . This book was released on 1999 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text originally prepared for a class. Includes course outline, assignments and supporting materials.

Tax Agreement

Author : The Government of the United States of America
Publisher : Good Press
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.4/5 (64 download)

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Book Synopsis Tax Agreement by : The Government of the United States of America

Download or read book Tax Agreement written by The Government of the United States of America and published by Good Press. This book was released on 2020-12-08 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a legal document detailing an agreement between the USA and The Peoples Republic of China. It was made to avoid double taxation and tax avoidance on income. It shows exactly what can and cannot be done under law and by whom. It became law in 1987.

Aspen Treatise for Introduction To United States International Taxation

Author : James R. Repetti
Publisher : Aspen Publishing
ISBN 13 : 1543827241
Total Pages : 369 pages
Book Rating : 4.5/5 (438 download)

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Book Synopsis Aspen Treatise for Introduction To United States International Taxation by : James R. Repetti

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.