Taxation of international transactions

Author: Charles H. Gustafson
Publisher: West Group
ISBN: 9780314149305
Format: PDF, Kindle
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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.

Federal Taxation of Property Transactions

Author: David L. Cameron
Publisher: LexisNexis
ISBN: 0327176903
Format: PDF, Mobi
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Two significant complications affect the taxation of property transactions. The first complication is the special treatment of capital gains and losses. The second complication arises from the time value of money. This book aims to provide students with an appreciation for these two significant complexities through the descriptive materials and problems presented. Chapter 1 introduces the concepts of basis and realization that are fundamental to the taxation of all transactions involving property. Chapter 2 follows with the effects of taxing gains and losses from capital assets differently from ordinary gains and losses. Chapter 3 deals with liabilities, which are essentially the opposite of assets or property, so that they can be considered negative property. Chapter 4 covers the rules applicable to the capitalization of costs incurred in the creation or acquisition of property and the recovery of those costs through a variety of expensing, amortization, and depreciation provisions. Chapter 5 covers non-recognition transactions (other than transfers involving partnerships, corporations or trusts) in which gain or loss is not recognized on disposition but is deferred through the mechanism of substituted basis. Chapter 6 deals with deferred compensation issues and other special problems arising in executive compensation arrangement using employer stock or stock options that reflect the lure of capital gain treatment. Chapter 7 covers the complexities that arise from the cliché that property is a bundle of rights, particularly when the ownership and long-term right to possession is divided under a lease or similar arrangement. Finally, Chapter 8 covers a number of special provisions that affect the deductibility of losses, including the wash sales rules, limitations on related party transactions, the at-risk and passive loss rules, and losses arising in certain leasing transactions. This eBook features links to Lexis Advance for further legal research options.

State and Local Taxation

Author: Jerome R. Hellerstein
Publisher: West Group
ISBN: 9780314153760
Format: PDF, ePub
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This law school casebook contains the most recent cases dealing with such issues as jurisdiction to tax out-of-state corporations, taxation of electric-power generating capacity and contaminated property, use tax collection responsibilities, and multiple and discriminatory taxation of nonresidents. In addition, this edition focuses on the rapidly expanding issues raised by state taxation of electronic commerce. It also includes the latest U.S. Supreme Court cases of general significance, as well as a section devoted to fundamental sales tax reform reflected in the states? Streamlined Sales Tax Project.

Understanding Nonprofit and Tax Exempt Organizations

Author: Nicholas P. Cafardi
Publisher: LexisNexis
ISBN: 1579110401
Format: PDF, ePub, Mobi
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Understanding Nonprofit and Tax Exempt Organizations is a guide for the law student or practitioner who is looking to understand the law governing the nonprofit, tax exempt sector. This text deals with the many types of tax exempt organizations; the rules, regulations and limitations imposed on tax exempt organizations by the courts, the Internal Revenue Code (IRS) and the Treasury Regulations (the Regulations); the charitable contribution and fundraising issues affecting tax exempt organizations; the unrelated business income tax, excise taxes and intermediate sanctions imposed on tax exempt organizations; and the rules regarding private foundations. This new Second Edition reflects recent changes in the law made by the Pension Protection Act of 2006 and the Patient Protection and Affordable Care Act of 2010. The Second Edition of Understanding Nonprofit and Tax Exempt Organizations begins with an introduction to nonprofit organizations by discussing the relevant law in general, as nonprofits are governed by state law. Next, tax exempt organizations are discussed, by first giving the reader the background on where such organizations fit in the nonprofit sector; why the organizations are given preferential tax treatment; what form these organizations take; and how such organizations are governed and dissolved. The Second Edition also provides detailed explanations of the various rules, regulations and tests they must follow in order to obtain or retain their tax exempt status as well as the consequences for failure to comply.

Selected Sections on United States International Taxation

Author: DANIEL J. LATHROPE
Publisher: Foundation Press
ISBN: 9781640208223
Format: PDF, ePub
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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 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).

Partnership Taxation

Author: George K. Yin
Publisher: Wolters Kluwer Law & Business
ISBN: 1454879599
Format: PDF, ePub
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Partnership Taxation, Third Edition is a concise, tightly-edited casebook, written by Distinguished Professor of Law and Taxation George K. Yin, and Richard B. Stephens Eminent Scholar in Taxation at the University of Florida Levin College of Law Karen C. Burke, that focuses on core principles and policies so that students can learn the major patterns and themes of partnership taxation. Key Features of the New Edition: • Economic substance doctrine guidance and partnership audit rules enacted in 2015 • Proposed regulations implementing section 704(c)(1)(C) for contributed built-in loss property • Final regulations under section 706 when partners’ interests vary during the year • Proposed regulations under sections 707 and 752 on disguised sales, fee waivers, and sharing of partnership liabilities • Proposed regulations under section 751(b) addressing shifts in ordinary income

Federal Wealth Transfer Taxation Cases and Materials

Author: Paul McDaniel
Publisher: Foundation Press
ISBN: 9781609300098
Format: PDF, Kindle
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This edition continues the comprehensive, yet flexible, presentation of prior editions. It explores technical and policy issues and is adaptable for use in a single course covering basic wealth transfer taxation or a sequence of such courses at either the J.D. level or LL.M. level. It includes approximately 300 problems, designed to help students master the material covered in each chapter. Within each section, the book moves from the straightforward to the more complex, empowering the professor to select the appropriate level of complexity for her course. It thoroughly integrates all changes in the law through May 1, 2015, including case law, legislation, regulations, rulings, and other administrative pronouncements.

International Taxation

Author: Philip F. Postlewaite
Publisher:
ISBN: 9781611638875
Format: PDF, ePub, Docs
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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.