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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 2021 edition is notably shorter in length and a fraction of the price of the leading competition. The new volume contains: (1) all relevant changes made by the Covid and Taxpayer Certainty Acts (Pub. L. No. 116-260), and the American Rescue Plan Act of 2021 (Pub. L. No 117-21); (2) changes to IRS regulations since 2020, (3) the 2016 United States Model Income Tax Convention, and (4) the inflation-adjusted items for 2021 (Revenue Procedure 2020-45).
This 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. The new volume contains all relevant changes to IRS regulations since 2016 and the inflation-adjusted items for 2017 are included.
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 2017 edition is notably shorter in length and a fraction of the price of the leading competition. The new volume contains all relevant changes to IRS regulations since 2016 and the inflation-adjusted items for 2017 are included (Revenue Procedure 2016-55).
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.
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
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).
Now available as an eBook, The 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.
Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246