International taxation in a nutshell

✍ Scribed by Doernberg, Richard L

• Publisher: West Academic Publishing
• Year: 2016
• Tongue: English
• Leaves: 630
• Series: Nutshell series
• Edition: Tenth edition
• Category: Library

✦ Synopsis

This book provides an introduction to the US law of international taxation. It summarizes the law, offering some attention to the purposes of the various legal rules. The book is divided into three parts. First it gives an introduction to the fundamentals of US international taxation and the source rules. The second part addresses the US activities of foreign taxpayers, i.e. investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profit tax and the provisions affecting foreign investment in US real estate. The third part is directed at foreign activities of US citizens and residents.

"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."--Publisher  Read more...

Abstract:

This Nutshell not only addresses the fundamentals of US international taxation, but it also offers insight into tax planning considerations. Building on both academic and private sector careers, the author has used his experience to distil the complexities of real-world tax considerations into a clearly written, straightforward presentation of the key international tax concepts.  Read more...

✦ Table of Contents

Content: Introduction --
Basic U.S. jurisdictional tax principles --
Source rules --
Taxing rules --
The role of income tax treaties --
Filing, withholding, and reporting requirements --
Introduction to U.S. business activity in foreign countries --
The foreign tax credit --
Intercompany pricing --
Controlled foreign corporations and related provisions --
Foreign currency --
International tax-free transactions --
Tax arbitrage and economic substance --
International boycott and foreign bribery provisions.

✦ Subjects

In