Education - Practical Guide to U.S. Taxation of International Transactions

Practical Guide to U.S. Taxation of
International Transactions

Authors/Editors:
Michael S. Schadewald, Ph.D., CPA and Robert J.Misey, Jr., J.D., MBA and LL.M.

ISBN: 978-0-8080-1719-6
Date Published: 8/07

Suggested List Price: $101.00
Net Bookstore Price: $80.80

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: Basic Principles, U.S. Taxation of Foreign Income, U.S. Taxation of Foreign Persons, and International Tax Practice and Procedure:

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.

Part IV covers issues common to both outbound and inbound activities, including inter-company transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

Written by noted tax practitioners, teachers and authors, Michael S. Schadewald and Robert J. Misey, Jr., this book is an indispensable reference guide for all those involved in U.S. taxation of cross-border transactions.

PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME

Overview of U.S. Taxation of International Transactions

Tax Jurisdiction

Source of Income Rules

PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS

Foreign Tax Credit

Deemed Paid Foreign Tax Credit

Anti-Deferral Provisions

Foreign Currency Translation and Transactions

Export Benefits

Planning for Foreign Operations

State Taxation of Foreign Operations

PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS

Foreign Persons Investing in the United States

Foreign Persons Doing Business in the United States

Planning for Foreign-Owned U.S. Operations

PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS

Transfer Pricing

Income Tax Treaties

Cross-Border Transfers and Reorganizations

International Tax Practice and Procedure

Teaching Package and Ancillary Support

For classroom help, chapter summaries and discussion questions are provided in a separate Instructor's Guide that is available to adopting instructors and their students. These questions present practical problems and are designed to help the student determine what to do in the situations presented. The Instructor's Guide also includes examination questions.

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To order Practical Guide to U.S. Taxation of International Transactions , use the following specifications:

Title:	Practical Guide to U.S. Taxation of International Transactions
Authors:	Michael S. Schadewald, Ph.D., CPA and Robert J.Misey, Jr., J.D., MBA and LL.M.
Prices:	$101.00 List/$80.80 Net (Reflects 20% Bookstore Discount)
Availability:	8/07
Item Number:	0-5211-400
ISBN:	978-0-8080-1719-6
Publisher:	CCH Tax and Accounting
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