Foreign Tax Credits,
by Bernard Moens, International Tax Manager for
Pricewaterhouse Coopers LLP (Offer #28361001)
This insightful commentary provides a comprehensive explanation of the complex and critical rules of utilizing foreign tax credits to minimize a company’s worldwide global tax rate. You’ll find a thorough examination of foreign tax credits complete with examples and practical analysis. Also included are useful practice tools, including flowcharts on the definition and character of foreign tax credits.
Allocation and Apportionment of Expenses,
by Robert Feinschreiber (Offer #28391001)
In Allocation and Apportionment of Expenses, Feinschreiber focuses on the process of allocating and apportioning expenses for a wide range of international tax computations, including:
U.S. Portfolio Investments,
by Ronald A. Marini, International Tax Attorney
with Marini & Associates, P.A. (Offer #28301001)
This Commentary covers the basic principles of the source-of-income rules and the statutory basis for taxation of foreign taxpayer’s portfolio and passive income necessary to determining the source of income, U.S. or foreign, and the U.S. tax consequences of international transactions. Convenient practice tools are included with a variety of practical fact patterns typically experienced by international tax practitioners.
U.S. Tax Withholding on Payments to Foreign Persons,
by Ruth Ann Schneider (Offer #28322001)
To ensure that the appropriate amount of U.S. tax is paid by foreign taxpayers, whether or not such taxpayers file a U.S. tax return, the Code requires any person paying certain amounts to foreign persons to withhold the appropriate amount as an agent of that foreign person. U.S. Tax Withholding on Payments to Foreign Persons provides an insider’s look into this complicated area. It focuses on the circumstances under which the relevant taxing authority maintains effective jurisdiction over the payor of the income amount but not the recipient of the income, such as when U.S. source income is paid to a foreign person. Ruth Ann Schneider has advised on non-resident alien withholding tax reporting and compliance issues for banks, broker-dealers and foreign central security depositories, and has negotiated with foreign tax officials to design international tax arrangements for withholding tax at-source on securities.
Information Reporting on Foreign Operations,
by Janet Rappaport, Director of International Tax
Planning for Fluor Corporation (Offer #28341001)
CCH’s Information Reporting on Foreign Operations is a complete explanation of what information must be collected and what information must be reported to the United States government regarding foreign operations. It sets forth the United States compliance requirements and, to the extent necessary, the substantive areas of the law governing a particular transaction. Also contains time saving and comprehensive practitioner tools with explanations of each information or filing requirement, plus sample forms and sample attachments to forms.
Foreign Currency Transactions,
by Jeffrey L. Olin, Senior Manager in Arthur
Andersen LLP’s International Tax Services Group (Offer #28371001)
Jeffrey Olin provides a critical analysis of U.S. taxation of transactions involving the use of foreign currency. He focuses on determining the timing of income or loss recognition, the amount of income or loss, the character of the income or loss as capital or ordinary, and the source of the gain or loss as foreign or domestic. Includes flowcharts that carefully track all of the critical steps needed in these computations.
Value-Added Taxes and E-Commerce,
by Karl Frieden, Mike Loten and Jackie Hubbard
(Offer #28311001)
E-commerce has developed over the last decade as companies have seen the way in which computerization, and the Internet in particular, can significantly accelerate business procedures. The aim of this Commentary is to explain how VAT legislation applies to e-commerce supplies. It also seeks to provide an indication of potential future changes to current legislation and how these changes may impact e-commerce transactions. Includes practice tools consisting of sample case studies, country checklists, recent pronouncements, and sample documents.
Estate Planning for Foreign Income and Property,
by G. Warren Whitaker, Esq., Partner, Hughes and
Whitaker, in New York (Offer #28381001)
The determination of whether a taxpayer is subject to U.S. taxation on its estate is a crucial task in estate planning. U.S. persons (including U.S. corporations and U.S. trusts) are subject to U.S. income tax on their worldwide income and are also subject to U.S. estate and gift tax on their worldwide assets. Non-U.S. persons are subject to U.S. income tax only on their U.S.-source income and are subject to U.S. estate and generation-skipping transfer taxes only on U.S.-situs property. Estate Planning for Foreign Income and Property provides a thorough explanation of the impact of foreign income on property estate planning.
U.S. Real Property Investments of Nonresidents,
by Richard Andersen, Partner in the New York
office of Arnold & Porter (Offer #28321001)
Richard Andersen delivers a thorough examination of the tax consequences of key investment activities and possible regulatory obligations.
The analysis of tax consequences focuses on:
Possible regulatory obligations discussed include a range of federal reporting obligations under the aegis of the U.S. Commerce, Agriculture and Treasury departments, as well as limitations on foreign ownership of local real estate by some states.