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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Introduction to United States International Taxation 6th ed isbn 9789041136565

Introduction to United States International Taxation 5th ed

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ISBN13: 9789041123602
ISBN: 9041123601
New Edition ISBN: 9789041136565
Previous Edition ISBN: 9041106197
Published: May 2005
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: Out of print



The 2005 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 ten specific 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
  • he 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
  • 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. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act.

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.

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Subjects:
Other Jurisdictions , Taxation, USA
Contents:
Recommended by Dr Roxan of LSE
for Tax LLM 2007/2008;
Preface.
1. Introduction.
2. The US Income Tax System: General Description.
3. Jurisdictional Principles.
4. Source Rules.
5. Income Taxation of Nonresident Aliens and Foreign Corporations.
6. Taxation of Foreign Source Income of US Persons: The Foreign Tax Credit.
7. Treatment of Foreign Business Operations and Investments by US Persons.
8. Transfer Pricing.
9. Special Treatment of Foreign Income.
10. Foreign Currency Issues.
11. Income Tax Treaties.
12. Wealth Transfer Taxation.