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The Taxation Of Controlled Foreign Corporations
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Book Synopsis The Taxation of Controlled Foreign Corporations by : John Prebble
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.
Book Synopsis Controlled Foreign Company Legislation by : Organisation for Economic Co-operation and Development
Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Book Synopsis Controlled Foreign Companies by : Lee Burns
Download or read book Controlled Foreign Companies written by Lee Burns and published by . This book was released on 1992 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is an explanation of Australia's CFC rules. It places the legislation in context, provides a framework for analysing problems and describes the new regime in detail.
Book Synopsis Proposal Relating to Current U.S. Taxation of Certain Operations of Controlled Foreign Corporations (H.R. 2889--American Jobs and Manufacturing Preservation Act of 1991) and Related Issues by : United States. Congress. House. Committee on Ways and Means
Download or read book Proposal Relating to Current U.S. Taxation of Certain Operations of Controlled Foreign Corporations (H.R. 2889--American Jobs and Manufacturing Preservation Act of 1991) and Related Issues written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1991 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 The Taxation of Controlled Foreign Corporations by : John Prebble QC
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble QC and published by . This book was released on 2015 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 1987, New Zealand taxpayers could avoid tax by establishing foreign corporations in which they held a controlling shareholding in low tax jurisdictions. This avoidance could occur in two ways. First, through using the foreign corporation to intercept passive income, such as interest or royalties, that would otherwise be taxed to the shareholders. Secondly, by using a foreign corporation as an investment vehicle for accumulated profits, thus sheltering investment income that would otherwise accrue to the shareholders. Six countries, the United States of America, Canada, France, the Federal Republic of Germany, and Japan, were sufficiently concerned about these problems to enact controlled foreign corporation legislation. Broadly, these countries adopt two methods to determine which income will be subject to taxation: the transactional approach and the jurisdictional approach. The jurisdictional approach is simple, relative to the transactional approach, but for all countries, the legislation is complicated. The author compares the relative merits of each country's legislation, concluding that the United Kingdom offers the most satisfactory model with the lowest compliance and administrative costs. In 1993, New Zealand adopted controlled foreign company legislation modelled on the United Kingdom's approach.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Book Synopsis Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries by : Daniel Sandler
Download or read book Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Book Synopsis CFCs--investment of Earnings in United States Property by : Philip Fried (Lawyer)
Download or read book CFCs--investment of Earnings in United States Property written by Philip Fried (Lawyer) and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investments of earnings and profits by controlled foreign corporations in United States property. This Portfolio discusses the circumstances under which such investments may result in the taxation to the company's U.S. shareholders of a portion of the company's earnings and profits, and it explains the rules governing the computation of such income inclusion. It describes the possibility of unexpected results from the operation of the §956 rules, and it suggests planning possibilities to avoid pitfalls. Among the matters discussed are the definition of the term "United States property" and the exceptions thereto; calculations of the amount of a controlled foreign corporation's earnings and profits invested in United States property and the effect of distributions on such calculations; special rules regarding the taxation of U.S. shareholders, including the applicable foreign tax credit rules; and tax planning opportunities."
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 1995 with total page 868 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
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 CFCs--general Overview by : Lowell D. Yoder
Download or read book CFCs--general Overview written by Lowell D. Yoder and published by . This book was released on 2010-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "Describes the general rules for U.S. income taxation of United States shareholders of controlled foreign corporations (CFCs) under Subpart F. It begins with a discussion of the background and legislative history of Subpart F. A detailed analysis is provided of the ownership tests that must be satisfied for Subpart F to apply, including such key terms as "controlled foreign corporation," "United States person," and "United States shareholder." This portfolio also describes the categories of items included in U.S. shareholders' income under Subpart F, and the rules for determining the amounts includible in income and the U.S. tax treatment. It further provides an overview of the tax results to U.S. shareholders of various transactions involving CFCs, including the organization and reorganization of a CFC, CFC distributions, and liquidations and dispositions of CFCs. Finally, it describes the rules coordinating Subpart F with other special rules that apply to foreign entities and summarizes the return and compliance rules that apply to CFCs."
Book Synopsis International Taxation by : Joseph Isenbergh
Download or read book International Taxation written by Joseph Isenbergh and published by CCH. This book was released on 2006 with total page 966 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Income Taxation by : Robert J. Peroni
Download or read book International Income Taxation written by Robert J. Peroni and published by CCH. This book was released on 2008 with total page 2356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compiled by a team of distinguished law professors, the 2008-2009 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.
Book Synopsis CFC Legislation, Tax Treaties and EC Law by : Michael Lang
Download or read book CFC Legislation, Tax Treaties and EC Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
Book Synopsis Supplemental Statistics of Income by : United States. Internal Revenue Service
Download or read book Supplemental Statistics of Income written by United States. Internal Revenue Service and published by . This book was released on 1979 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt:
