Practical Guide to U.S. Taxation of International Transactions (11th Edition)

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

Published: Aug 13, 2018
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$190



ISBN: 9780808050247
Product Number: 10032341-0005
Volumes: 1
Update Frequency: Bi-yearly
688 Pages

Practical Guide to U.S. Taxation of International Transactions (11th 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.

Written by noted tax practitioners, teachers and authors, Michael S. Schadewald and Robert J. Misey, Jr., this book is an indispensable reference guide for all those involved in U.S. taxation of cross-border transactions. The 11th edition of the book includes the international provisions of the Tax Cuts and Jobs Act of 2017.

  • Table of Contents
  • Practical Guide to U.S. Taxation of International Transactions (11th Edition)

    Topics and Content


    The book is organized into four parts:

    • 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
    • Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.
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