Introduction to United States International Taxation av Repetti James R., Ring Diane M., Shay Stephen - 9789403523859 - Jure bokhandel


Introduction to United States International Taxation
Författare:Repetti James R. , Ring Diane M. , Shay Stephen
Titel:Introduction to United States International Taxation
Upplaga:7 uppl.
Omfång:288 sid.
Ämnesord:Skatterätt , Internationell rätt , Utländsk rätt

Pris: 1744 SEK exkl. moms


ntroduction to United States International Taxation, now in its seventh edition, is an outstanding reference work for the tax community that introduces the application of the United States (U.S.) international taxation system to taxpayers investing or transacting business in the U.S. and other countries. Clearly and concisely, it enumerates the principles adopted by the U.S. in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or overseas.

What’s in this book:

- The compendium 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

- basic jurisdictional principles adopted by the U.S. concerning the application of its income tax to international investment and business transactions

- the U.S. rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from U.S. sources

- primary mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. persons

- income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules

- special treatment under FDII of a U.S. corporation’s export of goods, services and intangible rights

- general intercompany 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, and

- wealth transfer tax system, including modifications made by estate and gift tax treaties

The authors have extensively discussed and incorporated references to the Internal Revenue Code provisions under discussion, relevant Treasury Regulations and other administrative material and important cases that have arisen.

How this will help you:

This pragmatic book will prove to be an ideal reference source for non-U.S. tax practitioners, tax professors and students both within and outside the U.S., and others seeking a structural framework within which a U.S. tax problem can be placed.



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. Treatment of Foreign Business Operations and Investments by US Persons

CHAPTER 7. Formation, Reorganization, and Liquidation of Foreign Corporations: Section 367

CHAPTER 8. Foreign Investment Activities by US Persons Utilizing Foreign Corporations

CHAPTER 9. Taxation of Foreign Source Income of US Persons: The Foreign Tax Credit

CHAPTER 10. Limitations on the Foreign Tax Credit

CHAPTER 11. Special Treatment of Foreign Income

CHAPTER 12. Transfer Pricing

CHAPTER 13. Foreign Currency Issues

CHAPTER 14. Income Tax Treaties

CHAPTER 15. Wealth Transfer Taxation

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