Author: Joseph Isenbergh
This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Third Edition is divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.
Author: Howard E. Abrams,Richard L. Doernberg
Previous edition, 2nd, published in 1990.
Reform and Challenges in Times of Uncertainty
Author: Jorge Atria,Constantin Groll,Maria Fernanda Valdés
Category: Political Science
This study of taxation in Latin America takes a novel approach to the subject, using a framework that posits three dimensions for studying taxes—historical, relational, and transnational. The book argues that: first, taxation should be understood as a relational concept and tax systems as a function of a strategic nexus between the state and society; second, that any analysis of tax systems across Latin America needs to take historical legacies of national tax systems into account; and finally, that transnational phenomena have significant implications for tax regime dynamics in Latin America. The essays included provide diverse and representative insights for a new understanding of taxation in Latin America and highlight the bottlenecks to the development of sustainable tax systems in the region, exploring new links between academic research and policy-making.
Author: Richard Doernberg
Publisher: West Academic Publishing
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.
Author: Paul R. McDaniel,Hugh J. Ault,James R. Repetti
Publisher: Kluwer Law International
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: Daniel N. Shaviro
Publisher: Oxford University Press
Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.
Materials, Text, and Problems
Author: Charles H. Gustafson,Robert J. Peroni,Richard Crawford Pugh
Publisher: West Academic Publishing
Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Corporate and Individual
Author: Philip F. Postlewaite,Mitchell B. Weiss
Category: Corporations, Foreign
This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.
Author: MARVIN A.. ZELENAK CHIRELSTEIN (LAWRENCE.),Lawrence Zelenak
Publisher: Foundation Press
This highly-acclaimed text explains the conceptual basis of federal income taxation. It is designed to help students quickly pull together the entire subject for end-of-semester review and provide perspective about where a topic fits within the federal income tax scheme. While focusing on the present income tax, the text provides an explanation of the often-discussed consumption tax and contrasts the two taxes in a note at the end of the volume. The new edition reflects developments since the thirteenth edition, including many changes made by the Tax Cuts and Jobs Act of 2017--the most significant federal tax legislation in more than thirty years.
Author: Richard Schmalbeck,Lawrence Zelenak,Sarah B. Lawsky
Publisher: Wolters Kluwer Law & Business
Unique in its structure, Federal Income Taxation, Fifth Edition presents core materials that cover the basics of tax law and then offers supplemental "cells" at the end of the book that are self-contained units with more in-depth discussion of certain topics. Professors and students will benefit from: A thoroughly updated text that incorporates the extensive changes to the Code enacted by the Tax Cuts and Jobs Act of 2017 New cases reflecting developments since the previous edition. A new cell on the taxation of Bitcoin and other cryptocurrency. Core text (about 500 pages) that covers the leading cases and explains the substantive tax law that is essential to a basic understanding of federal income tax law and principles. Novel "Cells," self-contained, optional units at the end of the book that supplement the core text by presenting additional material and treating a limited number of topics in greater detail. Notes and questions providing background information and placing the cases and statutes in context. More than 150 problems throughout the core text and cells that challenge students to apply theory to specific situations. An annual "inflation supplement" issued every December that provides updated problems and answers to reflect inflation adjustments for the upcoming year, as well as updated tables where relevant.
Author: Brian J. Arnold,Michael McIntyre
Publisher: Kluwer Law International
Category: Business & Economics
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.
Author: Allison Christians,Samuel A. Donaldson,Philip F. Postlewaite
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.
Key Concepts and Current Research
Author: Yaniv Hanoch,Andrew Barnes,Thomas Rice
The field of behavioural economics can tell us a great deal about cognitive bias and unconscious decision-making, challenging the orthodox economic model whereby consumers make rational and informed choices. But it is in the arena of health that it perhaps offers individuals and governments the most value. In this important new book, the most pernicious health issues we face today are examined through a behavioral economic lens. It provides an essential and timely overview of how this growing field of study can reframe and offer solutions to some of the biggest health issues of our age. The book opens with an overview of the core theoretical concepts, after which each chapter assesses how behavioral economic research and practice can inform public policy across a range of health issues. Including chapters on tobacco, alcohol and drug use, physical activity, dietary intake, cancer screening and sexual health, the book integrates the key insights from the field to both developed and developing nations. Also asking important ethical questions around paternalism and informed choice, this book will be essential reading for students and researchers across psychology, economics and business and management, as well as public health professionals wishing for a concise overview of the role behavioral economics can potentially play in allowing people to live healthier lives.
Author: Craig Elliffe
Category: Business enterprises, Foreign
Written by international tax law specialist Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand's international tax law and double taxation agreements and transfer pricing regime. The book is designed to provide readers with an understanding of the legal principles and concepts which underpin international tax law and cross-border transactions and with practical guidance designed to assist them to navigate their way through this complex topic. It begins with an introductory chapter explaining the history and concept of international taxation and the way in which New Zealand and other nations deal with international taxation transactions. The next four chapters provide comprehensive coverage of residence-base taxation; source-based taxation; and taxation of source based income. The final two chapters deal with double tax agreements and allocation of profits (thin capitalisation).
Author: Jean-Frédéric Morin,Amandine Orsini
Category: Business & Economics
Aligning global governance to the challenges of sustainability is one of the most urgent environmental issues to be addressed. This book is a timely and up-to-date compilation of the main pieces of the global environmental governance puzzle. The book is comprised of 101 entries, each defining a central concept in global environmental governance, presenting its historical evolution, introducing related debates and including key bibliographical references and further reading. The entries combine analytical rigour with empirical description. The book: offers cutting edge analysis of the state of global environmental governance, raises an up-to-date debate on global governance for sustainable development, gives an in-depth exploration of current international architecture of global environmental governance, examines the interaction between environmental politics and other fields of governance such as trade, development and security, elaborates a critical review of the recent literature in global environmental governance. This unique work synthesizes writing from an internationally diverse range of well-known experts in the field of global environmental governance. Innovative thinking and high-profile expertise come together to create a volume that is accessible to students, scholars and practitioners alike.
Author: Robert J. Peroni,Charles H. Gustafson
Category: Business & Economics
Compiled by a team of distinguished law professors, the 2018-2019 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations--Selected Sections is a popular companion to an international tax coursebook for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office -- and between classroom and dorm. The book features a reader-friendly large 7-1/4 x 10 format with new larger type fonts for enhanced readability.
The People, Places & Ideas Fueling a Movement
Author: Lindsey Tramuta
The city long-adored for its medieval beauty, old-timey brasseries, and corner cafés has even more to offer today. In the last few years, a flood of new ideas and creative locals has infused a once-static, traditional city with a new open-minded sensibility and energy. Journalist Lindsey Tramuta offers detailed insight into the rapidly evolving worlds of food, wine, pastry, coffee, beer, fashion, and design in the delightful city of Paris. Tramuta puts the spotlight on the new trends and people that are making France’s capital a more whimsical, creative, vibrant, and curious place to explore than its classical reputation might suggest. With hundreds of striking photographs that capture this fresh, animated spirit, The New Paris shows us the storied City of Light as never before.