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Synopsis
A Practical Guide to US Taxation of International Transactions provides the reader with a practical command of the basic concepts and issues surrounding US taxation of international transactions, with an emphasis on those areas of international taxation generally deemed to be essential to tax practitioners. This new edition has been completely updated to reflect important developments since the book was last published in 1998. Transfer pricing and tax treaties are given special attention in the revision and a new section on IRS procedure is offered. Also greatly enhanced is the discussion of choice of entities and the check-the-box regulations, certainly one of the hottest topics in US international tax. Even with increased coverage, the book maintains its initial mission of providing a well-written and concise explanation of the subject that is accessible to all those who toil over US international tax issues. The book is organized into three parts: Basic Principles, US Taxation of Foreign Income, and US Taxation of Foreign Persons, which discusses the following topics in detail: PART 1 - Tax Jurisdiction; - Source of Income Rules; PART II - Foreign Tax Credit; - Transfer Pricing; - Anti-Avoidance Provisions Governing Foreign Corporations; - Foreign Sales Corporations; - Foreign Currency Translation and Transactions; - Tax Treaties; - Planning of Foreign Operations; PART III - Foreign Persons Investing in the United States; - Foreign Persons Doing Business in the United States. Appendices illustrate various applicable tax forms at the end of each Part. Also reproduced is the latest US Model Income Tax Treaty. This book is an indispensable reference guide for all those involved in international taxation.
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Synopsis
Providing the reader with a practical command of the basic concepts and issues surrounding US taxation of international transactions, this text places an emphasis on those areas of international taxation generally deemed to be essential to tax practitioners. This edition has been updated to reflect important developments since the book was published in 1998. Transfer pricing and tax treaties are given special attention in the revision and a new section on IRS procedure is offered. Also greatly enhanced is the discussion of choice of entities and the check-the-box regulations, certainly one of the hottest topics in US international tax. Even with increased coverage, the book maintains its initial mission of providing a concise explanation of the subject that should be accessible to all those who toil over US international tax issues.
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A Practical Guide to U.S. Taxation of International Transactions
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