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Vol 24 No 12 Dec 19/Jan 20

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Merkin and Flannery on the Arbitration Act 1996

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Essentials of United States Taxation

ISBN13: 9789041109644
ISBN: 9041109641
Published: July 1999
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £276.00

Despatched in 7 to 9 days.

Where there's trade, there's taxation. And more often than not these days, that means United States taxation. This book clearly explains basic structural features and accounting issues, corporate and partnership taxation, and the rules governing international transactions, both inbound and outbound.

It provides concise answers to such questions as:-

  • what is the US tax treatment of mergers and acqusitions?;
  • how are joint ventures and other hybrid entities taxed in the United States?;
  • how does the US foreign tax credit work?;
  • what are the most tax-beneficial ways to form a business in the United States?;
  • and how can special profit and loss allocations under US partnership law be used in international transactions?
It helps to provide a clear ""picture"" of the US tax system, yet the book is also of great value as a quick reference when a US tax problem needs to be solved.

Other Jurisdictions , USA
Part 1: General Principles.
Overview of Taxation in the United States.
Federal Income Taxation: Structural Issues.
Federal Income Tax: Conceptual Issues.
Legislative, Administrative and Judicial Aspects.
Part 2: Corporate Taxation.
The Corporate Double Tax.
Forming a Corporation.
The Corporation as a Taxable Entity.
Cash and Property Distributions.
Stock Dividends.
Tainted Stock.
Taxable Acquisitions.
Combining Tax Attributes.
Penalty Provisions.
S Corporations.
Part 3: Partnership Taxation.
The Structure of Partnership Taxation.
Determining Distributive Shares.
A Partner's Outside Basis.
Nonliquidating Distributions.
A Partner's Transactions with the Partnership.
Acquisitions of Partnership Interests.
Dispositions of Partnership Interests.
Loss Limitations.
Optional Basis Adjustments.
Partnership-Level Issues.
Part 4: International Taxation.
Basic U.S.
Jurisdictional Tax Principles.
Taxing Rules.
Source 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.
Foreign Sales Corporations.
International Boycott and Foreign Bribery Provisions.
Estate and Gift Taxation for Resident and Nonresident Aliens.