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Taxation of currency gains and losses considered.
" ... 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).
The authors observe that consumption taxation is superior to income taxation because it does not penalize saving and investment and propose that the U.S. income tax system be completely replaced by a progressive consumption tax. They argue that the X tax, developed by the late David Bradford, offers the best form of progressive consumption taxation for the United States and outline concrete proposals for the X tax's treatment of numerous specific economic issues.
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.
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.
This volume, by Joseph Gold, discusses some of the major letgal effects of fluctuating exchange rates in both public international law and national law. The problems and similarities in the solutions are reviewed, and the author recommends further developments in the law.