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" ... analyzes the issues relating to the deduction by an employer for a "reasonable allowance" under [section] 162(a) for compensation paid with regard to personal services rendered. It discusses in depth the factors applied in determining reasonableness, the necessity for the actual performance of services, situations where a deduction for reasonable compensation is not allowable, and other aspects of reasonable compensation. Various tax planning and controversy considerations also are discussed"--Portfolio description (p. iii).
This publication describes how enterprises are taxed on foreign exchange gains and losses resulting from currency fluctuations and analyses the consequences of differences in country practices.
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.
Is utopia possible? Maybe not a perfect society, but is it possible to maximize the happiness of society? This book proposes that it is, indeed, possible to, at least, greatly improve the happiness of society by structuring the tax code according to 2 very simple economic principles that anyone can understand. It will greatly reduce inequality and give most people a much better start in life. Economic output can also be increased by changing the tax code to promote work.This book explains the history of wealth creation, and why the wealthy are rich. It also debunks the many arguments used to promote tax breaks for the wealthy.If this tax policy could be enacted, it would end economic slavery, and show how the world could potentially live in peace! This book also suggests a much better way to vote so that better policies can be implemented, thus reducing the influence of money and corruption in politics.
Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Report on the implications of fluctuations in foreign exchange rates on the taxation of the ordinary income and capital gains of enterprises and reviews of member countries practices.