International Taxation
International Taxation
Islam, Adnan
John Wiley & Sons Inc
09/2020
304
Mole
Inglês
9781119756491
614
Descrição não disponível.
Chapter 1 1-1 Overview of U.S. Corporate International Taxation 1-1 Summary 1-2 U.S. Outbound Tax Concepts 1-3 U.S. Inbound Tax Concepts 1-4 Other fundamental U.S. international tax concepts 1-5 International tax fundamental concepts 1-6 Recognition of income 1-8 Introduction of International Tax Provisions enacted by the TCJA 1-10 Introduction and listing of U.S. international tax provisions 1-11 U.S. Export Tax Incentive through an IC-DISC 1-15 Chapter 2 2-1 Foreign Branches 2-1 Operating through a foreign branch - summary 2-2 Form 8832, "Entity Classification Election"-"check-the-box" election 2-8 Threshold of liability to foreign tax 2-10 Foreign currency issues as applied to branches, or QBUs 2-11 QBU 2-14 Section 988 transactions 2-22 Dispositions of nonfunctional currency 2-24 Translations with respect to debt instruments 2-26 U.S. dollar approximate separate transactions method 2-30 Chapter 3 3-1 Determining Source of Income 3-1 Personal property 3-9 Chapter 4 4-1 Allocation and Apportionment of Deductions 4-1 Allocation and apportionment of expenses, losses, and other deductions to U.S. and foreign-source income 4-2 Allocation and apportionment of certain deductions 4-5 Allocation and apportionment of interest expense 4-6 Special apportionment rules for partnerships 4-11 Special apportionment rules for corporations 4-12 Special allocations of interest expense 4-13 Research and experimentation expenditures 4-15 Chapter 5 5-1 U.S. Foreign Tax Credit System 5-1 FTC system post-TCJA overview and status 5-2 Internal Revenue Code sections dealing with foreign taxes 5-3 FTC expanded rules and examples 5-18 Creditable foreign taxes 5-25 Timing and recognition issue 5-27 Partnerships, LLCs (taxed as U.S. partnerships), and S corps 5-33 Chapter 6 6-1 Outbound International Tax Provisions under Tax Cuts and Jobs Act 6-1 Note to Reader or Practitioner 6-3 CFCs and Subpart F - Outline 6-5 Foreign base company sales income-Examples 6-15 FBC Services Income-Example and details 6-21 TCJA outbound international tax provisions 6-23 PFICs 6-43 Transfers of property by U.S. persons to foreign corporations - Section 367 6-46 Chapter 7 7-1 Inbound Taxation: U.S. Withholding Tax & Tax Treaty Concepts 7-1 Threshold for U.S. inbound taxation 7-3 U.S. trade or business > Effectively Connected Income (ECI) 7-6 Thin capitalization - interest expense limitation rules 7-10 FIRPTA - Section 897 7-14 U.S. inbound tax reporting obligations 7-17 IRC Chapter 3 - U.S. source withholding tax 7-18 IRC Chapter 3 withholding tax rules 7-20 FDAP (not ECI) 7-22 FDAP - Interest payment 7-23 FDAP - Dividends 7-25 FDAP - Royalties 7-28 FDAP - Rents 7-29 FDAP - Compensation for services 7-30 FDAP income 7-31 Gains from sale of personal property (for example, capital gains) 7-32 ECI exemption 7-33 Withholding tax obligations and procedures 7-34 Payment of withholding tax 7-37 Penalties for failure to withhold 7-39 Backup withholding 7-41 Partnership allocations 7-42 Withholding agent's payment and reporting requirements - U.S. partnership 7-44 IRC Chapter 4 - FATCA "withholding" 7-45 Summary of U.S. tax treaties and conventions 7-48 U.S. bilateral income tax treaties 7-52 Chapter 8 8-1 Transfer Pricing and BEPS Overview 8-1 Summary of U.S. Transfer Pricing rules 8-2 BEPS 8-26 Glossary Glossary 1 Index Index 1 Solutions Solutions 1 Chapter 1 Solutions 1 Chapter 2 Solutions 1 Chapter 3 Solutions 3 Chapter 4 Solutions 4 Chapter 5 Solutions 5 Chapter 6 Solutions 7 Chapter 7 Solutions 8 Chapter 8 Solutions 12
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Outbound; Inbound; Domestic Production; Branch; QBU; Functional Currency; Sourcing; Allocation; Apportionment; Foreign Tax Credit; FTC; Effectively Connected Income; CFC; PFIC; Tax Treaties; Conventions; Withholding; FATCA; Transfer Pricing; FDII; GILTI; BEAT; ITTF19
Chapter 1 1-1 Overview of U.S. Corporate International Taxation 1-1 Summary 1-2 U.S. Outbound Tax Concepts 1-3 U.S. Inbound Tax Concepts 1-4 Other fundamental U.S. international tax concepts 1-5 International tax fundamental concepts 1-6 Recognition of income 1-8 Introduction of International Tax Provisions enacted by the TCJA 1-10 Introduction and listing of U.S. international tax provisions 1-11 U.S. Export Tax Incentive through an IC-DISC 1-15 Chapter 2 2-1 Foreign Branches 2-1 Operating through a foreign branch - summary 2-2 Form 8832, "Entity Classification Election"-"check-the-box" election 2-8 Threshold of liability to foreign tax 2-10 Foreign currency issues as applied to branches, or QBUs 2-11 QBU 2-14 Section 988 transactions 2-22 Dispositions of nonfunctional currency 2-24 Translations with respect to debt instruments 2-26 U.S. dollar approximate separate transactions method 2-30 Chapter 3 3-1 Determining Source of Income 3-1 Personal property 3-9 Chapter 4 4-1 Allocation and Apportionment of Deductions 4-1 Allocation and apportionment of expenses, losses, and other deductions to U.S. and foreign-source income 4-2 Allocation and apportionment of certain deductions 4-5 Allocation and apportionment of interest expense 4-6 Special apportionment rules for partnerships 4-11 Special apportionment rules for corporations 4-12 Special allocations of interest expense 4-13 Research and experimentation expenditures 4-15 Chapter 5 5-1 U.S. Foreign Tax Credit System 5-1 FTC system post-TCJA overview and status 5-2 Internal Revenue Code sections dealing with foreign taxes 5-3 FTC expanded rules and examples 5-18 Creditable foreign taxes 5-25 Timing and recognition issue 5-27 Partnerships, LLCs (taxed as U.S. partnerships), and S corps 5-33 Chapter 6 6-1 Outbound International Tax Provisions under Tax Cuts and Jobs Act 6-1 Note to Reader or Practitioner 6-3 CFCs and Subpart F - Outline 6-5 Foreign base company sales income-Examples 6-15 FBC Services Income-Example and details 6-21 TCJA outbound international tax provisions 6-23 PFICs 6-43 Transfers of property by U.S. persons to foreign corporations - Section 367 6-46 Chapter 7 7-1 Inbound Taxation: U.S. Withholding Tax & Tax Treaty Concepts 7-1 Threshold for U.S. inbound taxation 7-3 U.S. trade or business > Effectively Connected Income (ECI) 7-6 Thin capitalization - interest expense limitation rules 7-10 FIRPTA - Section 897 7-14 U.S. inbound tax reporting obligations 7-17 IRC Chapter 3 - U.S. source withholding tax 7-18 IRC Chapter 3 withholding tax rules 7-20 FDAP (not ECI) 7-22 FDAP - Interest payment 7-23 FDAP - Dividends 7-25 FDAP - Royalties 7-28 FDAP - Rents 7-29 FDAP - Compensation for services 7-30 FDAP income 7-31 Gains from sale of personal property (for example, capital gains) 7-32 ECI exemption 7-33 Withholding tax obligations and procedures 7-34 Payment of withholding tax 7-37 Penalties for failure to withhold 7-39 Backup withholding 7-41 Partnership allocations 7-42 Withholding agent's payment and reporting requirements - U.S. partnership 7-44 IRC Chapter 4 - FATCA "withholding" 7-45 Summary of U.S. tax treaties and conventions 7-48 U.S. bilateral income tax treaties 7-52 Chapter 8 8-1 Transfer Pricing and BEPS Overview 8-1 Summary of U.S. Transfer Pricing rules 8-2 BEPS 8-26 Glossary Glossary 1 Index Index 1 Solutions Solutions 1 Chapter 1 Solutions 1 Chapter 2 Solutions 1 Chapter 3 Solutions 3 Chapter 4 Solutions 4 Chapter 5 Solutions 5 Chapter 6 Solutions 7 Chapter 7 Solutions 8 Chapter 8 Solutions 12
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