Practical Guide to U.S. Taxation of International Transactions (10th Edition)

Author(s): Michael S. Schadewald, Robert J. Misey

Published: Sep 21, 2015
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$160




ISBN: 9780808040842
Product Number: 10032341-0004
Volumes: 1
Update Frequency: Bi-yearly
688 Pages

Practical Guide to U.S. Taxation of International Transactions (10th Edition) 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.

The Practical Guide to U.S. Taxation of International Transactions (10th Edition) is now available in an eBook format which you can download to your computer instantly.

  • Table of Contents
  • Practical Guide to U.S. Taxation of International Transactions (10th Edition)

    Topics and Content


    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
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