International Taxation: U.S. Taxation of Foreign Persons and Foreign IncomeCCH, 2006 |
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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International Taxation: U.S. Taxation of Foreign Persons and ..., Volume 2 Joseph Isenbergh No preview available - 2006 |
Common terms and phrases
Aiken amount Article beneficial owner branch profits tax business profits capital gains chapter clause conduit controlled foreign corporation country of source debt deduction dividends domestic reverse hybrid effectively connected enterprise example exemption financing arrangement financing entity financing transactions fiscally transparent flat rate tax force of attraction foreign person half resident alien HavenCo imposed income tax treaties individual interest holder interest paid intermediate entity Internal Revenue Code item of income limitation Luxembourg Netherlands Antilles partnership pattern payee payment percent permanent establishment qualified intermediary Regulations under section Revenue Ruling reverse hybrid entity royalties section 877 shareholder specific subject to U.S. tax haven tax regime tax system tion trade or business treaty benefits treaty country treaty protection treaty provisions U.S. business U.S. citizens U.S. corporation U.S. income tax U.S. Model Treaty U.S. resident U.S. tax laws U.S. taxation U.S. Treasury U.S.-source income United Kingdom withholding agent withholding tax withholding under section
Popular passages
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.