International taxation / Bret Wells.
2022
INTERNET
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Title
International taxation / Bret Wells.
Published
St. Paul : West Academic, [2022]
Copyright
©2022
Call Number
INTERNET
Edition
Fifth edition.
ISBN
9781636597614 (electronic bk.)
1636597610 (electronic bk.)
9781636597744
1636597610 (electronic bk.)
9781636597744
Description
1 online resource (492 pages) : illustrations
System Control No.
on1344337161
(WestAcademic_OCoLC)1344337161
(WestAcademic_OCoLC)1344337161
Summary
This helpful study aid addresses the international taxation aspects of the U.S. tax system. In recent years, there has been an effort among the G-7 nations to better align their domestic tax laws. As a result, principles and enforcement mechanisms found in the U.S. tax system increasingly may resemble those of other nations. However, even though there may be similarities in the design of the tax laws of different nations, ultimately the study of international taxation represents a study of the laws of a particular nation. Thus, this book focuses on the study of U.S. taxation as applied to economic activity with an international element. The Fifth Edition is divided into three sections: common elements of international taxation for both inbound and outbound taxation, inbound U.S. taxation, and outbound U.S. taxation. Special attention is focused on base erosion and profit shifting strategies and the resulting complexity that has been added to the U.S. tax regime to address this phenomenon in the inbound and outbound context. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.
Bibliography, etc. Note
Includes bibliographical references.
Source of Description
Print version record.
Other Editions
Revision of: Isenbergh, Joseph. International taxation. Fourth edition. St. Paul, MN : Foundation Press : West Academic Publishing, [2020] 9781684679249 (OCoLC)1141780237
Available in Other Form
Print version: Wells, Bret (Law teacher). International taxation. Fifth edition. St. Paul, MN : Foundation Press, [2022] 9781636597744 (OCoLC)1338687728
Record Appears in
Table of Contents
U.S. taxation in the international setting
Nationality and residence for taxation
The source of income
International transfer pricing
U.S. taxation of foreign persons: passive investment income
U.S. taxation of foreign persons: taxation of a trade or business
Income tax treaties
Inbound base protection measures that backstop inbound taxation
Outbound U.S. taxation
Direct foreign investment: the foreign tax credit regime
Controlled foreign corporations
Passive Foreign Investment Companies (PFICs)
Dispositions, liquidations, and reorganizations of controlled foreign corporations and incorporations of foreign branches
Miscellaneous foreign incentives regimes.
Nationality and residence for taxation
The source of income
International transfer pricing
U.S. taxation of foreign persons: passive investment income
U.S. taxation of foreign persons: taxation of a trade or business
Income tax treaties
Inbound base protection measures that backstop inbound taxation
Outbound U.S. taxation
Direct foreign investment: the foreign tax credit regime
Controlled foreign corporations
Passive Foreign Investment Companies (PFICs)
Dispositions, liquidations, and reorganizations of controlled foreign corporations and incorporations of foreign branches
Miscellaneous foreign incentives regimes.