International Taxation: U.S. Taxation of Foreign Persons and Foreign Income

Front Cover
 

Contents

Table of Contents
civ
Coordination of Deemed Paid Taxes
cix
Corporate Divisions under Section 367b
cxi
U S Taxation of Interest Income from Passive
cxiii
Source of Miscellaneous Income and Gains
cxxv
Reserved
cxxix
The Basic Plumbing of Foreign Corporations
cxxxiv
Residence for Transfer Taxation
cxxxv
10
47
48
48
1
52
1
57
Withholding in International Taxation
The Residence of Corporations
4
1
1
4
4

Preface
cxxxix
Background and Case
cxli
1
cxliii
Allocation of Interest Paid by Foreign
cxliv
Special Note on Sources and Citations
cxlvii
Remittances
cxlix
Reserved
cliv
Introduction and Overview
1
Special Source Rules
2
3
3
5
5
48
6
40
10
5
1
Identity and Deferral
19
Reserved
27
28
28
Tax Benefit Principles
30
15
32
Grand Chart of Dividends
1
5
5
1
11
E Permanent Establishments Arising
17
1
19
Reserved
22
F Attribution of Business Profits to Permanent
23
Allocation of Research and Development Expenses
25
U S Taxation of Nonresident Aliens
32
Foreign Investment Companies Controlled
33
Employees Performing Artists Athletes Students
1
The Situs of Corporations
4
10
10
Fixed
16
17
17
19
7
Source of Miscellaneous
17
Allocation of Interest Paid
23
26
26
1
1
B Taxation of Gains from the Sale
3
6
6
9
9
11
11
16
13
Double Taxation Credits
1
4
7
9
9
1
18
Source
21
The Asset Method of Apportionment
22
B The U S Tax System
26
30
30
U S Taxation of Interest
32
1
41
The BranchLevel
43
G Disclosure Rules for TreatyBased
45
9
47
9
48
1
51
1
1
The Situs of Trusts and Estates
5
6
6
4
7
Source of Gains from the Sale
15
22
22
1
24
Reserved
1
24
4
Translating the Income
16
International Corporate Reorganizations
18
Allocation of Other
25
1
26
6
6
A Corporations
7
Reserved
9
Foreign Governments International
10
11
11
12
12
13
13
Taxation of Excess Distributions
14
B Recognition and Computation of Specific Items
18
The Basic Plumbing
19
25
23
G Regulations on Cost Sharing
27
Specific Transactions and Methods
28
U S Taxation of Passive
34
9
38
28
1
1
7
Inbound
1
Foreign Income from
2
Mechanics
1
5
5
8
8
10
10
12
12
13
13
14
14
17
17
E The Payee is not the Beneficial Owner of
21
Background and Overview
30
H Obligations and Liabilities of Withholding
31
1
1
Grand Chart of Dividends and DeemedPaid
4
9
9
B The Boundaries of Services and Transfers
10
17
17
23
19
1
1
5
5
Credit for Taxes Paid by Foreign
1
9
9
Table of Cases
Table of Cases
1
Table of Internal Revenue Code Sections
15
16
16
17
17
18
18
19
19
B Former U S Citizens Subject to Section 877
27
Table of Treasury Regulations
47
49
49
B Decided Cases on Creditable Taxes before
55
6
60
B Matching of Dividends with Pre1987
64
Table of Internal Revenue Rulings
77
Table of U S Model Tax Treaty Articles
83
Credit for Taxes Paid by Foreign
1-1
Regulations on the Performance of Services
1-4
Special Provisions
1-7
Treasury Regulations
1-10
1
1-12
11
1-13
G Foreign Base Company Income
1-16
17
1-17
Foreign Estates
1-18
U S Taxation of Passive
1-33
Deduction of Qualified Production Activity Income
1-34
Residence of Partnerships
1-41
B Distributions of Previously Taxed
1-45
U S Taxation of Foreign Income
1-48
1
1-50
1
1-56
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Page 28 - Mutual Agreement Procedure 1 . Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of...
Page 12 - Article the term permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise...
Page 28 - Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which...
Page 10 - permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term 'permanent establishment...
Page 6 - ... from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
Page 32 - Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.
Page 16 - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films...
Page 1 - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.

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