U. S. Income Taxation of Foreign Corporations and Non-resident Aliens PDF Download
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Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1132
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Book Description
Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1132
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Book Description
Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Corporations, Foreign
Languages : en
Pages : 496
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Book Description
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 32
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Book Description
Author: Sidney I. Roberts
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
Extensive handbook on the taxation of foreign corporations and nonresidents in the USA. Chapters include: general principles, tax patterns of foreign taxpayers, the foreign tax credit, definitions, residence and citizenship, trade or business within the United States, sources of income, withholding of tax at source, tax treaties, corporations used to avoid income tax on shareholders, and returns.
Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 148
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Book Description
Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages :
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Book Description
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 28
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Book Description
Author: Practising Law Institute
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages :
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Book Description
Author:
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 44
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Book Description
Author: James R. Repetti
Publisher: Kluwer Law International B.V.
ISBN: 9403523905
Category : Law
Languages : en
Pages : 458
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Book Description
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.
