International Taxation in a Nutshell

Author: Richard Doernberg
Publisher: West Academic Publishing
ISBN: 9781628105551
Format: PDF, Docs
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This nutshell not only addresses the fundamentals of U.S. international taxation, but it also offers insight into tax planning considerations. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In the truly global economy in which we live, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. Building on both academic and private sector careers, the author has used his experience to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts, including the most recent developments.

International taxation in a nutshell

Author: Richard L. Doernberg
Publisher: West Publishing Company
ISBN:
Format: PDF, Docs
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This 5x7.5" reference serves as an introduction to the US law of international taxation for law students, foreign lawyers, and US lawyers seeking an introduction or refresher. It overviews US tax laws governing international trade and investment, making frequent reference to the International Revenue Code and the Income Tax Regulations. Sections cover fundamentals of US international taxation, the US activities of foreign taxpayers, foreign activities of US citizens and residents, special US international tax provisions creating incentives and disincentives for certain conduct or transactions, and the effect of US transfer taxes on resident and nonresident aliens. c. Book News Inc.

Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen Burke
Publisher: West Academic Publishing
ISBN: 9781634607124
Format: PDF, ePub, Mobi
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This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised fifth edition reflects developments through September 2016, including proposed rules relating to compensatory profits interests and fee waivers, contributed built-in loss property, sharing of partnership liabilities and disguised sales, basis adjustments under �� 734(b), 743(b) and 755, and � 751(b) distributions.

Federal Estate and Gift Taxation in a Nutshell

Author: John K. McNulty
Publisher:
ISBN:
Format: PDF, Mobi
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Wealth Transfer Taxation; Constitutionality; The Federal Estate Tax, Gift Tax and Generation-Skipping Transfer Tax Outlined; Unification of Transfer Taxes; Gratuitous Transfers; Transfers During Life; Donative Intent; Consideration; Property; Transfer; Inclusion in the Gross Estate; Alternative Valuation Date; Liability for Tax; Incomplete Transfers; Transfers in Contemplation of Death; Retained Interests or Powers; Revocable Transfers; Special Valuation Rules and "Estate Freezes; " Jointly-Owned Property; Community Property; Property Settlements; Life Insurance; Annuities; Employee Death Benefits; Powers of Appointment; Inclusion; Valuation; Exemptions; Exclusions; Future Interests; Deductions (Charitable, etc.); Marital Deduction; Split Gifts; Unified Credit; International; Estate Planning; Reforms and Fundamental Alternatives.

Tax Procedure and Tax Fraud in a Nutshell

Author: Camilla E. Watson
Publisher: West Group
ISBN: 9780314146465
Format: PDF, ePub
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Reliable source on tax procedure and tax fraud helps bridge the gap between understanding "substantive" code provisions and preparing to represent a taxpayer in an Internal Revenue Service (IRS) dispute. Coverage includes IRS and treasury rulemaking; confidentiality and disclosure; audits and administrative appeals; statute of limitations; litigation considerations; penalties and collection process; liability; investigation; and tax crimes.

International Tax Primer

Author: Brian J. Arnold
Publisher: Kluwer Law International
ISBN: 9041188983
Format: PDF, ePub
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The international aspects of income taxation have become increasingly important as countries worldwide have become more economically integrated. International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. It grew out of the authors' work with the OECD in conducting seminars on international tax for tax officials in countries emerging from the collapse of the Soviet Union. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes: the role of the tax adviser; tax planning techniques; international double taxation; transfer pricing; anti-avoidance rules; tax treaties, including discussion of the OECD and UN Model Treaties; emerging issues, such as e-commerce and harmful tax competition.

Introduction to United States International Taxation

Author: Paul R. McDaniel
Publisher: Kluwer Law International
ISBN: 9041123601
Format: PDF
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The 2005 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 ten specific 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. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act . 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.

United States International Taxation

Author: Allison Christians
Publisher: LexisNexis
ISBN: 1422480313
Format: PDF, Docs
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This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross- border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.

International Taxation

Author: Joseph Isenbergh
Publisher:
ISBN: 9781599414416
Format: PDF, Docs
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This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Third Edition is divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.