United States International Taxation


Author: Allison Christians,Samuel A. Donaldson,Philip F. Postlewaite
Publisher: LexisNexis
ISBN: 0327174692
Category: Law
Page: 648
View: 9930

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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.

Corporate Taxation


Author: Charlotte Crane,Linda McKissack Beale
Publisher: LexisNexis
ISBN: 1422419991
Category: Corporations
Page: 466
View: 7359

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Selected Sections on United States International Taxation

2018
Author: DANIEL J. LATHROPE
Publisher: Foundation Press
ISBN: 9781640208223
Category:
Page: 730
View: 4455

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This uniquely affordable volume contains all of the relevant Internal Revenue Code provisions and Treasury Regulations necessary for introductory classes in United States international taxation. It is specially geared for use in two or three-unit international taxation courses, and includes essential legislation and regulations affecting U.S. taxation of foreign entities and of domestic entities whose income derives from outside the United States. Lathrope's 2018 edition is notably shorter in length and a fraction of the price of the leading competition. The new volume contains all relevant changes made by the Tax Cuts and Jobs Act (Pub. L. No. 115-97), changes to IRS regulations since 2017, and the inflation-adjusted items for 2018 are included (Revenue Procedure 2018-18 and Revenue Procedure 2017-58).

Federal Taxation of Property Transactions


Author: David L. Cameron,Elliott Manning
Publisher: LexisNexis
ISBN: 0327176903
Category: Law
Page: 1016
View: 1337

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Two significant complications affect the taxation of property transactions. The first complication is the special treatment of capital gains and losses. The second complication arises from the time value of money. This book aims to provide students with an appreciation for these two significant complexities through the descriptive materials and problems presented. Chapter 1 introduces the concepts of basis and realization that are fundamental to the taxation of all transactions involving property. Chapter 2 follows with the effects of taxing gains and losses from capital assets differently from ordinary gains and losses. Chapter 3 deals with liabilities, which are essentially the opposite of assets or property, so that they can be considered negative property. Chapter 4 covers the rules applicable to the capitalization of costs incurred in the creation or acquisition of property and the recovery of those costs through a variety of expensing, amortization, and depreciation provisions. Chapter 5 covers non-recognition transactions (other than transfers involving partnerships, corporations or trusts) in which gain or loss is not recognized on disposition but is deferred through the mechanism of substituted basis. Chapter 6 deals with deferred compensation issues and other special problems arising in executive compensation arrangement using employer stock or stock options that reflect the lure of capital gain treatment. Chapter 7 covers the complexities that arise from the cliché that property is a bundle of rights, particularly when the ownership and long-term right to possession is divided under a lease or similar arrangement. Finally, Chapter 8 covers a number of special provisions that affect the deductibility of losses, including the wash sales rules, limitations on related party transactions, the at-risk and passive loss rules, and losses arising in certain leasing transactions. This eBook features links to Lexis Advance for further legal research options.

International Taxation

Corporate and Individual
Author: Philip F. Postlewaite,Mitchell B. Weiss
Publisher: N.A
ISBN: 9781611638875
Category: Corporations, Foreign
Page: 1360
View: 5808

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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.

Tax Crimes (2015)


Author: John Townsend,Larry Campagna,Steve Johnson,Scott Schumacher
Publisher: LexisNexis
ISBN: 1630430897
Category: Law
Page: N.A
View: 2745

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This new title is one of six releases from the LexisNexis Graduate Tax Series. Tax Crimes, Second Edition (2015) 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 Assigned Readings emphasize the Code sections and other rule-based materials, including: the Department of Justice Criminal Tax Manual, the Internal Revenue Manual, the United States Sentencing Guidelines, and statutes governing other crimes which frequently are charged together with tax crimes, such as conspiracy, false statement, bankruptcy fraud, and currency offenses. This book addresses the numerous substantive and procedural issues that arise in the investigation, prosecution, and defense of tax crimes and related offenses. The early chapters of the book map the topography, providing an overview of criminal tax, describing the crimes under the Code and related crimes under other statutes, and developing the elements of and principal defenses to tax crimes. The middle chapters take a "life cycle" approach, tracking the stages of a criminal tax case from investigation to pretrial, trial, post-trial, and sentencing. Subsequent chapters address ancillary issues such as the forfeitures, disabilities, publicity, ethics, and civil tax liability and penalties. The concluding chapter summarizes the course and ties the various topics together with a comprehensive Problem. This eBook features links to for further legal research options.

Finance & Accounting for Lawyers


Author: Brian P. Brinig
Publisher: Business Valuation Resources Llc
ISBN: 9781935081715
Category: Business & Economics
Page: 313
View: 2248

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The principles of accounting and finance directly extend to contract issues, torts, business and securities matters, taxation issues, partnership disputes, gift and estate matters, to name only a partial list. These areas of jurisprudence are often based significantly on substantive financial questions, and their measurement can be the heart of the entire matter. The application of broad accounting principles to countless business transactions requires an understanding of the objectives of financial reporting and the needs of the users of financial information. Contrary to popular belief, accounting is not a mathematical formula or calculation, but rather an organized system that logically summarizes business transactions into useable information that is meaningful to management, creditors, business investors and other stakeholders. This text takes readers through the system of accounting and the development of financial statements. Complexities and limitations of accounting information are explored, culminating in a study of ratio analysis of financial statements to glean relevant insights. The objective of this introductory study of accounting is to provide a broad, workable knowledge base that will facilitate the use of accounting information as it relates to the practice of law.

Civil Tax Procedure


Author: David Maurice Richardson,Jerome Borison,Steve Johnson
Publisher: LexisNexis
ISBN: 1422417565
Category: Income tax
Page: 425
View: 6044

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Practical Guide to U.S. Taxation of International Transactions (11th Edition)


Author: Michael S. Schadewald,Robert J. Misey
Publisher: N.A
ISBN: 9780808050247
Category: Business & Economics
Page: N.A
View: 9462

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Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

International Income Taxation: Code and Regulations--Selected Sections (2018-2019 Edition)


Author: Robert J. Peroni,Charles H. Gustafson
Publisher: Cch
ISBN: 9780808050131
Category: Business & Economics
Page: N.A
View: 8349

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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.

Federal Income Tax

Code and Regulations--Selected Sections as of June 1, 2008
Author: Martin B. Dickinson
Publisher: CCH
ISBN: 9780808018636
Category: Business & Economics
Page: 2027
View: 7126

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CCH's Federal Income Tax: Code and Regulations--Selected Sections provides a selection of the Internal Revenue Code and Treasury Regulations pertaining to income tax. This popular volume reflects the collective judgment of seven distinguished tax teachers and provides an effective mix of official materials for individual and business undergraduate and graduate tax courses offered in law and business schools. It provides in one volume, the provisions most commonly addressed in income tax courses The book's highly readable 7-1/2" x 10" oversized page format make it easier to read for both professor and student. The book is an attractive alternative to the full text of the multi-volume Internal Revenue Code and Income Tax Regulations.

Federal Income Taxation


Author: Paul McDaniel,Martin McMahon, Jr.,Dennis Ventry, Jr.,Daniel Simmons,Bradley Borden
Publisher: Foundation Press
ISBN: 9781609302641
Category:
Page: 1465
View: 8369

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This casebook explores both the technical and policy issues associated with general principles of income taxation. The book is unrivaled in scope, depth of analysis, and flexibility. The materials facilitate focusing on either in depth coverage or broad policy issues for any particular topic. Within units, the material moves from the straight-forward to more complex rules, thus enabling each professor to make a decision as to the level of complexity which he or she wishes to reach in the course. The text can be used in a single course covering basic income taxation or a sequence of courses dealing with income taxation at either the J.D. or LL.M. level.

Taxation of Individual Income


Author: J. MARTIN. BURKE,Michael K. Friel
Publisher: N.A
ISBN: 9781531008727
Category:
Page: 1180
View: 2834

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The twelfth edition of Taxation of Individual Income approaches the study of individual income tax through the problem method. The text is designed as a series of self-contained chapters featuring a set of problems, assignments to pertinent Code and Regulation provisions, an overview of the chapter topic, and edited cases and administrative materials as well as self-assessment tools.

Law of Agency


Author: Gino Evan Dal Pont
Publisher: Butterworth-Heinemann
ISBN: 9780409324365
Category: Agency (Law)
Page: 797
View: 7439

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The most substantial Australian text on the law of agency. Part of the LexisNexis Butterworths Black and Silver hard cover series, the second edition of Law of Agency updates the both case law and legislation as it relates to agency law. The author discusses Australian law in both a local and international context. Since the first edition there have been High Court judgments and hundreds of decisions in common law courts. Importantly, the book incorporates the significant statutory changes in the Australian Capital Territory, New South Wales, Tasmania and other jurisdictions. The book is structured in the same manner as the first edition and takes you through agency law as it relates to tort, equity, company law, partnership law, banking law, professional responsibility, insurance law and the power of attorney.

Employee Benefits Law: Qualification and ERISA Requirements


Author: Kathryn J. Kennedy,Paul T. Shultz III
Publisher: LexisNexis
ISBN: 0327174889
Category: Law
Page: 774
View: 5294

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This title is part of the LexisNexis Graduate Tax Series. Employee Benefits Law: Qualification Rules and ERISA Requirements, Second Edition, differs from other employee benefits casebooks and practicing legal education materials in the following ways: • The book makes a clear delineation of the qualification requirements of the IRC applicable to employee benefit plans versus ERISA requirements. As such, most of the materials focus on pension and profit sharing plans. However, the tax rules applicable to welfare benefit plans and nonqualified deferred compensation plans are also discussed. • The book places a strong emphasis on planning and policy, focusing on the adoption, maintenance, and correction of such plans. • The substantive qualifications of the IRC are discussed in full. ERISA's fiduciary, enforcement, reporting, and disclosure standards are also set forth. Sophisticated realistic problems are an integral part of the materials, and are included throughout. These problems will require careful analysis and application of code and regulation provisions, administrative pronouncements, case law, and other relevant sources. Perhaps more important for a graduate tax program, the problems not only require careful analysis, but the application requires dealing with situations when the most careful reading of the materials does not supply an answer. An additional, in-depth, take-home problem may be used as the basis for class discussion or a graded written assignment. Employee Benefits Law is divided into two sections. Part 1 addresses the specific qualification requirements of the tax code applicable to all employee retirement plans, from both the employee and employer perspective. Part II addresses tax rules applicable to welfare benefits and nonqualified deferred compensation plans and ERISA rules applicable generally to all employee benefits plans. Thereafter, the ERISA rules applicable to employee retirement plans and welfare plans are covered.

Tax Controversies

Practice and Procedure
Author: Leandra Lederman,Stephen W. Mazza
Publisher: LexisNexis/Matthew Bender
ISBN: 9781422422632
Category: Tax administration and procedure
Page: 794
View: 5340

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Tax Administration Reform in China

Achievements, Challenges, and Reform Priorities
Author: John Brondolo,Zhiyong Zhang
Publisher: International Monetary Fund
ISBN: 147554734X
Category: Business & Economics
Page: N.A
View: 6250

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Tax administration improvements have contributed significantly to a doubling of China’s tax-to-GDP ratio and the substantial reduction in taxpayers’ compliance costs since the mid-1990s. This paper describes the key features of China’s tax administration and their evolution over the last 20 years. It also identifes emerging challenges to the tax system and areas where further tax administration improvements are needed to sustain tax revenue and reduce taxpayers’ compliance costs in the future.

Federal Income Taxation of Corporations, 3d, 2010 Supplement


Author: Paul R. McDaniel,Martin J. McMahon, Jr.,Daniel L. Simmons
Publisher: Foundation Press
ISBN: 9781599418162
Category: Law
Page: 50
View: 7748

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This 2010 supplement updates the casebook, which provides detailed information on federal income taxation of corporations. The casebook provides the tools for fast, easy, on-point research and includes selected cases designed to illustrate the development of taxation of corporations.