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Practical Guide to U.S. Taxation of International Transactions (13th Edition)

Practical Guide to U.S. Taxation of International Transactions (13th Edition)

作者： Michael S. Schadewald Ph.D., CPA; Robert J. Misey J.D., M.B.A., LL.M.
出版商： CCH U.S.
ISBN: 9780808058441
出版时间 August 2022
规格： Paperback , 688 pages
适应领域： U.S. ? 免责申明：
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Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice.

The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.
PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME
- Overview of U.S. Taxation of international Transactions
- Tax Jurisdiction
- Source of income Rules
PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS
- Foreign tax Credit
- Deemed Paid Foreign tax Credit
- Anti-Deferral Provisions
- Foreign Currency Translation and Transactions
- Export Benefits
- Planning for Foreign Operations
- State Taxation of Foreign Operations
PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS
- Foreign Persons Investing in the United States
- Foreign Persons Doing Business in the United States
- Planning for Foreign-Owned U.S. Operations
PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS
- Transfer Pricing
- Income tax Treaties
- Cross-Border Transfers and Reorganizations
- International tax practice and Procedure
Michael S. Schadewald, Ph.D., CPA, is on the faculty of the University of Wisconsin-Milwaukee, where he teaches graduate and undergraduate courses in business taxation. A graduate of the University of Minnesota, Professor Schadewald has published numerous articles in academic and professional journals, and has served on many editorial boards. He also co-authors CCH's Practical Guide to U.S. Taxation of International Transactions, and writes a column for CCH's "Journal of State Taxation."

Robert J. Misey, JR., J.D., M.B.A., LL.M., is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. in Milwaukee, Wisconsin. Mr. Misey concentrates his practice in the areas of tax controversies and international taxation. He previously worked as an attorney with the IRS Chief Counsel (International) in Washington, D.C. and as a large-case attorney in the Western and Southeast Regions. He has tried 23 cases before the U.S. Tax Court.

Mr. Misey received his Master of Laws degree, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer, and received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University. He is a member of the Tax Section of the District of Columbia, California, and Wisconsin bars and a former member of the Inn of Court at the U.S. Tax Court in Washington, D.C.

Mr. Misey often speaks on taxation at continuing education programs and has written numerous articles. He also teaches in the Master of Taxation program in the University of Wisconsin system. He is a co-author of a Practical Guide to U.S. Taxation of International Transactions, which is published by CCH, a Wolters Kluwer business.

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