U.S. Tax Aspects of Doing Business Abroad
Author : Michael L. Moore
Publisher :
Page : 774 pages
File Size : 17,18 MB
Release : 1991
Category : Business & Economics
ISBN :
Author : Michael L. Moore
Publisher :
Page : 774 pages
File Size : 17,18 MB
Release : 1991
Category : Business & Economics
ISBN :
Author :
Publisher :
Page : 12 pages
File Size : 35,96 MB
Release : 1988
Category : Income tax
ISBN :
Author : Michael L. Moore
Publisher :
Page : 459 pages
File Size : 23,12 MB
Release : 1983
Category : Corporations
ISBN :
Author : Michael L. Moore
Publisher :
Page : 474 pages
File Size : 32,2 MB
Release : 1983
Category : Corporations
ISBN :
Author : Michael Moore
Publisher :
Page : pages
File Size : 43,42 MB
Release : 2005
Category :
ISBN : 9780870517709
Author : United States. Internal Revenue Service
Publisher :
Page : 28 pages
File Size : 41,56 MB
Release : 1990
Category : Double taxation
ISBN :
Author : James R. Repetti
Publisher : Kluwer Law International B.V.
Page : 458 pages
File Size : 24,61 MB
Release : 2021-07-07
Category : Law
ISBN : 9403523905
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 :
Publisher :
Page : 56 pages
File Size : 49,6 MB
Release : 1996
Category : Aliens
ISBN :
Author : William John Gibbons
Publisher :
Page : 200 pages
File Size : 45,57 MB
Release : 1957
Category : Corporations, American
ISBN :
Author : James R. Repetti
Publisher : Aspen Publishing
Page : 369 pages
File Size : 34,33 MB
Release : 2021-12-28
Category : Business & Economics
ISBN : 1543827241
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.