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Pris: 1237 SEK exkl. moms  |  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 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 estates, 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;
- 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 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.
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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 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 estates, 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;
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 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.
Contents
About the Authors
Preface
CHAPTER 1 Introduction
CHAPTER 2 The United States Income Tax System: General Description
CHAPTER 3 Jurisdictional Principles
CHAPTER 4 Source Rules
CHAPTER 5 Income Taxation of Nonresident Aliens and Foreign Corporations
CHAPTER 6 Taxation of Foreign Source Income of United States Persons: The Foreign Tax Credit CHAPTER 7 Treatment of Foreign Business Operations and Investments by United States Persons
CHAPTER 8 Transfer Pricing
CHAPTER 9 Special Treatment of Foreign Income CHAPTER 10 Foreign Currency Issues
CHAPTER 11 Income Tax Treaties
CHAPTER 12 Wealth Transfer Taxation
Index
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