International Taxation in a Nutshell

Author: Richard Doernberg
Publisher: West Academic Publishing
ISBN: 9781628105551
Format: PDF, ePub
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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.

International taxation in a nutshell

Author: Richard L. Doernberg
Publisher: West Publishing Company
ISBN:
Format: PDF, ePub, Docs
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This 5x7.5" reference serves as an introduction to the US law of international taxation for law students, foreign lawyers, and US lawyers seeking an introduction or refresher. It overviews US tax laws governing international trade and investment, making frequent reference to the International Revenue Code and the Income Tax Regulations. Sections cover fundamentals of US international taxation, the US activities of foreign taxpayers, foreign activities of US citizens and residents, special US international tax provisions creating incentives and disincentives for certain conduct or transactions, and the effect of US transfer taxes on resident and nonresident aliens. c. Book News Inc.

Federal Estate and Gift Taxation in a Nutshell

Author: John K. McNulty
Publisher:
ISBN:
Format: PDF, Docs
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Wealth Transfer Taxation; Constitutionality; The Federal Estate Tax, Gift Tax and Generation-Skipping Transfer Tax Outlined; Unification of Transfer Taxes; Gratuitous Transfers; Transfers During Life; Donative Intent; Consideration; Property; Transfer; Inclusion in the Gross Estate; Alternative Valuation Date; Liability for Tax; Incomplete Transfers; Transfers in Contemplation of Death; Retained Interests or Powers; Revocable Transfers; Special Valuation Rules and "Estate Freezes; " Jointly-Owned Property; Community Property; Property Settlements; Life Insurance; Annuities; Employee Death Benefits; Powers of Appointment; Inclusion; Valuation; Exemptions; Exclusions; Future Interests; Deductions (Charitable, etc.); Marital Deduction; Split Gifts; Unified Credit; International; Estate Planning; Reforms and Fundamental Alternatives.

Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen Burke
Publisher: West Academic Publishing
ISBN: 9781634607124
Format: PDF, ePub
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This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised fifth edition reflects developments through September 2016, including proposed rules relating to compensatory profits interests and fee waivers, contributed built-in loss property, sharing of partnership liabilities and disguised sales, basis adjustments under �� 734(b), 743(b) and 755, and � 751(b) distributions.

International Taxation in America

Author: Brian Dooley
Publisher: AuthorHouse
ISBN: 1456725874
Format: PDF, ePub, Mobi
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"International Taxation in America" presents the most complete and indispensible guide to international taxation available in today's market. Author Brian Dooley, CPA, is a seasoned tax researcher and specialist in international tax and is among the very few experts who have experienced hundreds of international tax audits without a loss. Covering international taxation for businesses, the taxation of shareholders of foreign corporations, foreign tax credits, cross-border estate planning, and much more, Dooley offers meticulous research and clear explanations of hundreds of international tax-related issues. Whether the subject is tax haven corporations and trusts, reducing taxes through tax treaties, learning how Americans are taxed abroad, or estate planning for multi-national families, Dooley explains the subject in thorough and clear language. "International Taxation in America" provides valuable lessons for your enrichment, including useful links to help guide you online. You'll receive the level of information and expertise required to avoid mistakes and IRS scrutiny.

Federal Taxation of Property Transactions

Author: David L. Cameron
Publisher: LexisNexis
ISBN: 0327176903
Format: PDF, Mobi
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Two significant complications affect the taxation of property transactions. The first complication is the special treatment of capital gains and losses. The second complication arises from the time value of money. This book aims to provide students with an appreciation for these two significant complexities through the descriptive materials and problems presented. Chapter 1 introduces the concepts of basis and realization that are fundamental to the taxation of all transactions involving property. Chapter 2 follows with the effects of taxing gains and losses from capital assets differently from ordinary gains and losses. Chapter 3 deals with liabilities, which are essentially the opposite of assets or property, so that they can be considered negative property. Chapter 4 covers the rules applicable to the capitalization of costs incurred in the creation or acquisition of property and the recovery of those costs through a variety of expensing, amortization, and depreciation provisions. Chapter 5 covers non-recognition transactions (other than transfers involving partnerships, corporations or trusts) in which gain or loss is not recognized on disposition but is deferred through the mechanism of substituted basis. Chapter 6 deals with deferred compensation issues and other special problems arising in executive compensation arrangement using employer stock or stock options that reflect the lure of capital gain treatment. Chapter 7 covers the complexities that arise from the cliché that property is a bundle of rights, particularly when the ownership and long-term right to possession is divided under a lease or similar arrangement. Finally, Chapter 8 covers a number of special provisions that affect the deductibility of losses, including the wash sales rules, limitations on related party transactions, the at-risk and passive loss rules, and losses arising in certain leasing transactions. This eBook features links to Lexis Advance for further legal research options.

Tax Procedure and Tax Fraud in a Nutshell

Author: Camilla E. Watson
Publisher: West Group
ISBN: 9780314146465
Format: PDF, ePub, Mobi
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Reliable source on tax procedure and tax fraud helps bridge the gap between understanding "substantive" code provisions and preparing to represent a taxpayer in an Internal Revenue Service (IRS) dispute. Coverage includes IRS and treasury rulemaking; confidentiality and disclosure; audits and administrative appeals; statute of limitations; litigation considerations; penalties and collection process; liability; investigation; and tax crimes.

International Tax Primer

Author: Brian J. Arnold
Publisher: Kluwer Law International
ISBN: 9041188983
Format: PDF, ePub, Docs
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The international aspects of income taxation have become increasingly important as countries worldwide have become more economically integrated. International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. It grew out of the authors' work with the OECD in conducting seminars on international tax for tax officials in countries emerging from the collapse of the Soviet Union. The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes: the role of the tax adviser; tax planning techniques; international double taxation; transfer pricing; anti-avoidance rules; tax treaties, including discussion of the OECD and UN Model Treaties; emerging issues, such as e-commerce and harmful tax competition.

United States International Taxation

Author: Allison Christians
Publisher: LexisNexis
ISBN: 1422480313
Format: PDF, ePub, Docs
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This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross- border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.