Practical Guide to U.S. Taxation of International Transactions 2007

Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. Inhoudsopgave: PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME Overview of U.S. Taxation of International Transactions Basic Principles 101 (1) Tax Jurisdiction 101 (1) Source of Income Rules 101 (1) Taxation of U.S. Person`s Foreign Activities 102 (1) Foreign Tax Credit 102 (1) Deemed Paid Foreign Tax Credit 102 (1) Anti-Deferral Provisions 102 (1) Foreign Currency Translation and Transactions 102 (1) Taxation of Foreign Person`s U.S. Activities 103 (1) Foreign Persons Investing in the United States 103 (1) Foreign Persons Doing Business in the United States 103 (1) Issues Common to Outbound and Inbound Activities 104 (97) Transfer Pricing 104 (1) Income Tax Treaties 104 (97) Tax Jurisdiction Jurisdictional Issues 201 (1) Bases for Asserting Jurisdiction 201 (1) Territorial versus Credit Systems 201 (1) Tax Treaties 201 (1) Overview of U.S. Jurisdictional System 202 (1) Foreign Activities of U.S. Persons 202 (1) U.S. Activities of Foreign Persons 202 (1) Definition of Resident Alien 203 (1) Green Card Test 203 (1) Substantial Presence Test 203 (1) First Year of Residency 203 (1) Last Year of Residency 203 (1) Filing a Joint Return 203 (1) Exclusion for Foreign Earned Income 204 (1) Exclusion versus Credit 204 (1) Qualified Individuals 204 (1) Computing the Exclusion 204 (1) Housing Cost Allowance 204 (1) Electing the Exclusion 204 (1) Rules Regarding Expatriation 205 (1) A Policy Note Regarding the Current U.S. System 206 (1) Appendix 207 (94) Source-of-Income Rules Importance of Source Rule