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International Applications of U. S. Income Tax Law Inbound and Outbound Transactions

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ISBN-10: 0471482811

ISBN-13: 9780471482819

Edition: 2004

Authors: Ernest R. Larkins

List price: $176.95
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Description:

A clear, concise explanation of United States tax law's international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm's-length principles International Applications of U.S. Income Tax Law…    
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Book details

List price: $176.95
Copyright year: 2004
Publisher: John Wiley & Sons, Incorporated
Publication date: 11/20/2003
Pages: 400

Ernest R. Larkins is the E. Harold Stokes/KPMG Professor of Accounting at Georgia State University, where he teaches graduate courses in federal tax research and international taxation. He has published approximately 100 articles in various academic, law, and professional journals, as well as several chapters in books and monographs. He has received research fellowships from the Australian Taxation Studies Program (ATAX), University of New South Wales, and, for work conducted in Russia, the Society of International Business Fellows. He is an active member of the American Accounting Association and the American Taxation Association.

Preface
Generic Topics
Policy and Overview
International Tax Policy
Entity Selection
Generic Topics
Inbound Transactions
Outbound Transactions
Related Person Transactions
Jurisdiction to Tax
Tale of Two Systems
U.S. Jurisdiction
Double Taxation
Income Tax Treaties
Treaty Creation and Authority
Treaty Scope
Personal Service Income
Business Profit
Investment Income
Gain from Dispositions
Special Clauses
Source of Income
Fundamental Importance
General Source Rules
Interest Income
Dividend Income
Personal Service Income
Rent and Royalty Income
Gain from Selling Property
Other Source Rules
Allocation and Apportionment
Allocation to Classes
Apportionment to Groupings
Interest Deductions
Research and Experimental Deductions
Other Deductions
Inbound Transactions
Foreign Persons
Residency Tests
Counting Days
Dual Status Aliens
Important Elections
Nonbusiness Income
Fixed or Determinable
Annual or Periodical Income
Marginal Tax Rates
Nonbusiness Exemptions
Interest Stripping
Business Income
U.S. Trade or Business
Effectively Connected Income
Business Exemptions
Income Tax Calculations
Real Property Gains
U.S. Real Property Interests
U.S. Real Property Holding Corporations
Withholding Procedures
Structures for Holding U.S. Real Estate
Branch Taxes
Branch Profits Tax
Marginal Tax Rates
Branch Interest Tax
Outbound Transactions
Foreign Tax Credit
Creditable Taxes
Deemed Paid Taxes
Limitation Formula
Tax-Sparing Credit
Controlled Foreign Corporations
CFCs and U.S. Shareholders
Subpart F Income
Earnings Invested in U.S. Property
Constructive Dividends
Other Antideferral Provisions
Passive Foreign Investment Companies
Qualified Electing Funds
Foreign Personal Holding Companies
Export Incentives
Extraterritorial Income Exclusion
Domestic International Sales Corporations
U.S. Individuals Abroad
Foreign Earned Income Exclusion
Income Sourced in U.S. Possessions
Social Security Concerns
Related Person Transactions
Transfer Prices
General Principles
Loan of Funds
Performance of Services
Rental of Tangible Propert
Sale or License of Intangible Property
Sale of Tangible Property
Valuation Misstatements
Advance Pricing Agreements
Asset Transfers
Outbound Asset Transfers
Inbound Asset Transfers
External Asset Transfers
Glossary
Table of Statutes
Table of Regulations
Table of Cases
Table of Rulings
Index