This Portfolio examines the rules that apply to various forms of foreign corporate or partnership formations or restructurings under §367 and under related provisions such as §6038B.
This Portfolio addresses the withholding of U.S. federal income tax under §§1441–1443 of the Internal Revenue Code from payments of certain U.S. source income made to foreign persons.
This Portfolio discusses the three tax regimes that nonresident aliens and foreign corporations that conduct shipping or air transport activities within the U.S. may be subject to.
U.S. Taxation of Foreign Estates, Trusts and Beneficiaries explains the federal income, estate and gift taxation of foreign trusts and estates and their grantors and beneficiaries.
This Portfolio analyzes the U.S. federal income tax treatment of entities providing telecom infrastructure and services, including Internet Service and Telephony Providers.
This Portfolio analyzes the U.S. income tax laws applicable to non-U.S. citizens who are classified as “nonresident aliens” under the Internal Revenue Code.
This Portfolio analyzes the U.S. income tax laws applicable to nonresident alien students, teachers, and researchers who are living, working, and/or studying in the United States.
U.S. Income Taxation of Foreign Governments, International Organizations and Their Employees discusses the income tax exemptions under §§892, 893, and 895 of the Code.
U.S. Income Taxation of Foreign Corporations describes the Internal Revenue Code provisions applicable to foreign corporations.
U.S. Income Tax Treaties — U.S. Competent Authority Functions and Procedures addresses the administrative and competent authority procedures available under U.S. income tax treaties.
U.S. Income Tax Treaties — The Limitation on Benefits Article discusses in detail the limitation on benefits (LOB) article of U.S. income tax treaties.
This Portfolio focuses on the treatment in U.S. income tax treaties of income derived by an individual in his or her capacity as an independent worker or employee, government worker, director, artist or athlete, or student or business apprentice, and income realized in the form of pensions, social security benefits, annuities, alimony, or child support.
This Portfolio discusses the competent authority functions and procedures of Australia, Canada, France, Mexico, The Netherlands, and the United Kingdom.
Portfolio covers transfer pricing records requirements; audits, appeals and penalties; document requests; and competent authority consideration in transfer pricing cases.
This Portfolio describes the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organisation for Economic Co-operation and Development (OECD).
This Portfolio discusses the unique strategic and procedural considerations attendant to contesting through the administrative process and, if necessary, in litigation a transfer pricing dispute identified during the examination phase.
Transfer Pricing: Introductory Materials follows a transfer pricing scenario from the gathering of pricing information through all of the possible post–return procedural steps.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 presents the rules and practice related to transfer pricing in Korea, Australia, and Brazil.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, presents the rules and practice related to transfer pricing in Canada, Mexico, and Japan.
Transfer Pricing: European Rules and Practice, Part 2 contains a detailed explanation of the transfer pricing rules and practice in Denmark, Belgium, Italy, Sweden, and Switzerland.
Transfer Pricing: European Rules and Practice, contains detailed explanations of the transfer pricing rules and practice in France, the United Kingdom and Germany.
This Portfolio analyzes the economics of transfer pricing and the use of a company's internal data to assist in establishing and defending transfer prices.
This Portfolio presents a case study in selecting a transfer pricing methodology and analyzes: advance pricing agreements, cost sharing arrangements, and the use of joint ventures.
This Portfolio discusses the provisions of former §936, which allowed a credit to domestic corporations for certain business activities in Puerto Rico and the U.S. possessions.
The Foreign Tax Credit Limitation Under Section 904 discusses one part of the U.S. foreign tax credit mechanism—the foreign tax credit limitation under §904.
This Portfolio discusses the rules under §901 for determining what is a creditable income tax and the rules under §903 for determining what is a creditable “in-lieu-of” tax.
The Branch-Related Taxes of Section 884 analyzes the branch-related taxes of §884, i.e., the branch profits tax, the branch level interest withholding tax, and the excess interest tax.
The Allocation and Apportionment of Deductions sets forth and analyzes the rules for allocating and apportioning deductions in various contexts.
Tax Aspects of Foreign Currency examines U.S. taxation of transactions translating foreign currency into U.S. dollars.
Source of Income Rules analyzes the rules applicable in determining whether income is treated as from sources within the United States or from foreign sources.
This Portfolio discusses double taxation of U.S. citizens abroad, citizens who expatriate to avoid tax, tax treaties relevant to U.S. citizens and other taxes relevant to U.S. citizens.
Reporting Requirements Under the Code for International Transactions discusses special tax compliance issues for U.S. persons with foreign operations, subsidiaries, or other assets, and foreign persons with U.S. operations, subsidiaries, or other assets.
PFICs discusses the passive foreign investment company (“PFIC”) provisions and the attempt to deny the benefit of tax deferral to U.S. persons who invest in PFICs.
This Portfolio examines the principal U.S. tax issues that arise in international uses of entities treated as partnerships for U.S. tax purposes.
This Portfolio analyzes the U.S. wage withholding rules that apply to aliens working in the United States, and to U.S. citizens and certain aliens working in foreign countries.
This Portfolio analyzes the U.S. Social Security tax rules that apply to aliens working in the U.S., and to U.S. citizens and certain aliens working in foreign countries.
This Portfolio contains analysis of §902.
Foundations of U.S. International Taxation provides an introduction to and overview of the application of the U.S. income tax system in the international environment.
Foreign Personal Holding Companies examines U.S. taxation of U.S. shareholders of foreign personal holding companies.
Foreign Corporation Earnings and Profits explains how the earnings and profits (E&P) of foreign corporations are computed, accounted for, and applied for U.S. tax purposes.
Federal Taxation of Foreign Investment in U.S. Real Estate discusses the federal tax rules bearing upon foreign investment in U.S. real estate.
Export Tax Incentives examines the history of export tax incentives under the Internal Revenue Code and discusses rules pertaining to interest-charge domestic international sales corporations (IC DISCs), which currently constitute the only export tax incentive under the Code.
Controlled Foreign Corporations — Section 956 analyzes the federal income tax consequences under §956 of the Internal Revenue Code.
Subpart F—General describes the rules for the U.S. federal income taxation of shareholders of controlled foreign corporations(CFCs)under Subpart F of the Internal Revenue Code.
CFCs — Sections 959–965 and 1248 describes the rules that apply to the repatriation of the earnings and profits of a CFC under Subpart F of the Internal Revenue Code.
CFCs — Foreign Personal Holding Company Income provides a analysis of foreign personal holding company income, foreign base company income and “Subpart F income".
CFCs — Foreign Base Company Income (Other than FPHCI) focuses on the provisions of §954 other than those pertaining to foreign personal holding company income.
Business Operations in Vietnam provides information on the salient features of the business environment in Vietnam from both a tax and a general legal perspective.
Business Operations in Venezuela contains analysis of the tax system and discusses the significant features of tax law as applied to foreign investors conducting business in Venezuela.
Business Operations in the United Kingdom introduces potential investors and their advisers to the tax and other considerations relevant to business operations in the U.K.
This Portfolio introduces investors to the tax and legal issues relevant to businesses in the Virgin Islands of the U.S., Guam, American Samoa, and the Northern Mariana Islands.
Business Operations in the Republic of Korea deals with the taxes and tax problems most likely to be encountered by foreign firms doing business with the Republic of Korea.
Business Operations in the Republic of Ireland addresses in general terms the main legal, tax, and employment aspects of operating a business in Ireland.
Business Operations in the Republic of China (Taiwan) describes the types of entities that can conduct business and the relevant tax laws and regulations that govern them.
This Portfolio contains information designed to enable U.S. and other foreign investors to evaluate the legal and tax factors relevant to business operations in the Philippines.
This Portfolio provides companies and individuals considering or engaged in business operations in China with a general description of the relevant Chinese laws and regulations.
Business Operations in The Netherlands Antilles analyzes the existing legal framework affecting foreign investment and the system of taxation applying to business operations.
Business Operations in The Netherlands provides detailed information on the major aspects of Netherlands taxation of both foreign and domestic businesses.
Business Operations in the European Union provides a comprehensive guide to the legal issues affecting business in the European Union.
Business Operations in Sweden contains information enabling investors to determine the best method of conducting their operations from both a tax and a general legal point of view.
Business Operations in Spain contains information to enable businesses to determine the best method of conducting their operations from both a tax and a general legal perspective.
Business Operations in South Africa provides basic information relating to the tax and general legal problems affecting a foreign business conducting its operations in South Africa.
Business Operations in Singapore provides businesses and individuals interested in business operations with a description of the statutes and regulations governing business activities.
Business Operations in Russia introduces U.S. and other investors to the tax and other considerations relevant to carrying on business operations in Russia.
Business Operations in Puerto Rico offers background information on the relationship between Puerto Rico and the United States and provides a summary of the Puerto Rican legal system.
Business Operations in Poland summarizes the main business and tax laws of Poland and provides general background information concerning operations in the country.
Business Operations in New Zealand contains information to enable investors to determine the best method of conducting operations in New Zealand from a tax and legal perspective.