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Introduction to United States International Taxation, 6th Edition

Introduction to United States International Taxation, 6th Edition

作者： Stephen E. Shay; James R. Repetti; Diane M. Ring
出版商： Kluwer Law International
ISBN: 9789041136565
出版时间 February 2014
规格： Hardback , 232 pages
适应领域： U.S. ? 免责申明：
Countri(es) stated herein are used as reference only

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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.
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
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

Index

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