International Taxation Of Trust Income

Author : Mark Brabazon
Publisher : Cambridge University Press
ISBN 13 : 1108492258
Total Pages : 417 pages
Book Rating : 4.56/5 ( download)

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Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.

Author : John L. Peschel
Publisher : Warren Gorham & Lamont
ISBN 13 :
Total Pages : 228 pages
Book Rating : 4.86/5 ( download)

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Download or read book Federal Taxation of Trusts, Grantors, and Beneficiaries written by John L. Peschel and published by Warren Gorham & Lamont. This book was released on 1989 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : James R. Repetti
Publisher : Aspen Publishing
ISBN 13 : 1543827241
Total Pages : 369 pages
Book Rating : 4.48/5 ( download)

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Download or read book Aspen Treatise for Introduction To United States International Taxation written by James R. Repetti and published by Aspen Publishing. This book was released on 2021-12-28 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new 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 U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. The 7th Edition focuses on: General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights 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 U.S. dollar Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties Professors and students will benefit from: The ideal reference source for those seeking a structural framework in which an international tax problem can be placed. A treatise that can serve as a main text or a supplement to courses that deal in whole or in part with the United States tax system.

Author : James R. Repetti
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403523905
Total Pages : 458 pages
Book Rating : 4.03/5 ( download)

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Download or read book Introduction to United States International Taxation written by James R. Repetti and published by Kluwer Law International B.V.. This book was released on 2021-07-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) 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 the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the 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, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany 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; and 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. 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.

Author : Paul R. McDaniel
Publisher :
ISBN 13 : 9789041123602
Total Pages : 0 pages
Book Rating : 4.01/5 ( download)

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Download or read book Introduction to United States International Taxation written by Paul R. McDaniel and published by . This book was released on 2005 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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; the 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; and 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.

Author : Charles Bruce
Publisher : Springer
ISBN 13 :
Total Pages : 410 pages
Book Rating : 4.14/5 ( download)

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Download or read book United States Taxation of Foreign Trusts written by Charles Bruce and published by Springer. This book was released on 2000-03-30 with total page 410 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explanation and comments upon the U.S. tax and reporting rules applicable to foreign trusts. Examples of suggested courses of action for common problems are given throughout.

Author : Michael Honiball
Publisher : Siber Ink
ISBN 13 : 1920025774
Total Pages : 908 pages
Book Rating : 4.79/5 ( download)

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Download or read book International Tax written by Michael Honiball and published by Siber Ink. This book was released on 2011-03-15 with total page 908 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.

Author : Joseph Isenbergh
Publisher : CCH
ISBN 13 : 9780808016168
Total Pages : 918 pages
Book Rating : 4.64/5 ( download)

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Download or read book International Taxation written by Joseph Isenbergh and published by CCH. This book was released on 2006 with total page 918 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : Brian Dooley
Publisher : AuthorHouse
ISBN 13 : 1456736388
Total Pages : 374 pages
Book Rating : 4.85/5 ( download)

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Download or read book International Taxation in America written by Brian Dooley and published by AuthorHouse. This book was released on 2011-02-01 with total page 374 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Taxation in America presents the most complete and indispensible guide to international taxation available in todays 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. Youll receive the level of information and expertise required to avoid mistakes and IRS scrutiny.

Author : Emma Chamberlain
Publisher :
ISBN 13 : 9780414043350
Total Pages : 1679 pages
Book Rating : 4.59/5 ( download)

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Download or read book Trust Taxation written by Emma Chamberlain and published by . This book was released on 2011 with total page 1679 pages. Available in PDF, EPUB and Kindle. Book excerpt: Trust Taxation covers the taxation of UK resident and non-resident trusts explaining in detail the income tax, capital gains tax and inheritance tax treatment of the various different types of trusts. The book covers the tax consequences of creating and ending a trust, as well as the tax issues to consider during the lifetime of each type of trust and on distributions to beneficiaries. Part 1 contains an overview of trust law including recent case law on Hastings Bass, the categorisation of foreign entities, the new domicile and residence proposals and case law on residence and domicile generally. It also summaries the tax rules for foreign domiciliaries. Parts 2 to 4 explain the relevant legislation in detail as it relates to trusts, including discussion of entrepreneurs' relief, rollover relief, reservation of benefit, excluded property and relevant property trusts. Part 5 deals with special situations, including the family home, chattels, employee benefit trusts, pilot trusts, bare trusts, disabled trusts, will drafting, variations, business property relief and agricultural property relief, divorce and trusts.