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.
The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.
The book is organized into four parts:
PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME
- Overview of U.S. Taxation of International Transactions
- Tax Jurisdiction
- Source of Income Rules
PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS
- Foreign Tax Credit
- Deemed Paid Foreign Tax Credit
- Anti-Deferral Provisions
- Foreign Currency Translation and Transactions
- Export Benefits
- Planning for Foreign Operations
- State Taxation of Foreign Operations
PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS
- Foreign Persons Investing in the United States
- Foreign Persons Doing Business in the United States
- Planning for Foreign-Owned U.S. Operations
PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS
- Transfer Pricing
- Income Tax Treaties
- Cross-Border Transfers and Reorganizations
- International Tax Practice and Procedure
Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.
Written by noted tax practitioners, teachers and authors, Michael S. Schadewald and Robert J. Misey, Jr., this book is an indispensable reference guide for all those involved in U.S. taxation of cross-border transactions.
For classroom instruction, adopting instructors get the Instructor's Guide: Practical Guide to U.S. Taxation of International Transactions. The Instructor's Guide provides summaries of important key sections of each chapter along with chapter problems and solutions.
ABOUT THE AUTHORS:
Michael S. Schadewald, Ph.D., CPA, is on the faculty of the University of Wisconsin-Milwaukee, where he teaches graduate courses in multistate and international taxation. A graduate of the University of Minnesota, Professor Schadewald is a co-author of several books on multistate and international taxation, and has published more than 30 articles in academic and professional journals, including the CPA Journal, Journal of Taxation, The Tax Adviser, TAXES: The Tax Magazine, International Tax Journal, International Tax Notes, and Journal of International Accounting, Auditing and Taxation. Professor Schadewald has also served on the editorial boards of Journal of the American Taxation Association, International Journal of Accounting, International Tax Journal, Issues in Accounting Education, and Journal of Accounting Education.
Robert J. Misey, Jr., J.D., LL.M., M.B.A., is a shareholder in the law firm of Reinhart, Boerner, Van Deuren s.c. in Milwaukee. Mr. Misey focuses his practice in the areas of international taxation, transfer p
The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.
The book is organized into four parts:
PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME
- Overview of U.S. Taxation of International Transactions
- Tax Jurisdiction
- Source of Income Rules
PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS
- Foreign Tax Credit
- Deemed Paid Foreign Tax Credit
- Anti-Deferral Provisions
- Foreign Currency Translation and Transactions
- Export Benefits
- Planning for Foreign Operations
- State Taxation of Foreign Operations
PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS
- Foreign Persons Investing in the United States
- Foreign Persons Doing Business in the United States
- Planning for Foreign-Owned U.S. Operations
PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS
- Transfer Pricing
- Income Tax Treaties
- Cross-Border Transfers and Reorganizations
- International Tax Practice and Procedure
Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.
Written by noted tax practitioners, teachers and authors, Michael S. Schadewald and Robert J. Misey, Jr., this book is an indispensable reference guide for all those involved in U.S. taxation of cross-border transactions.
For classroom instruction, adopting instructors get the Instructor's Guide: Practical Guide to U.S. Taxation of International Transactions. The Instructor's Guide provides summaries of important key sections of each chapter along with chapter problems and solutions.
ABOUT THE AUTHORS:
Michael S. Schadewald, Ph.D., CPA, is on the faculty of the University of Wisconsin-Milwaukee, where he teaches graduate courses in multistate and international taxation. A graduate of the University of Minnesota, Professor Schadewald is a co-author of several books on multistate and international taxation, and has published more than 30 articles in academic and professional journals, including the CPA Journal, Journal of Taxation, The Tax Adviser, TAXES: The Tax Magazine, International Tax Journal, International Tax Notes, and Journal of International Accounting, Auditing and Taxation. Professor Schadewald has also served on the editorial boards of Journal of the American Taxation Association, International Journal of Accounting, International Tax Journal, Issues in Accounting Education, and Journal of Accounting Education.
Robert J. Misey, Jr., J.D., LL.M., M.B.A., is a shareholder in the law firm of Reinhart, Boerner, Van Deuren s.c. in Milwaukee. Mr. Misey focuses his practice in the areas of international taxation, transfer p
