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U.S. Taxation of International Operations: Key Knowledge

Author: Michael Tilton, CPA, J.D.
Publisher: AICPA
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U.S. Taxation of International Operations: Key Knowledge is packed with information for both organizations whose work extends beyond the U.S. and the CPAs who serve them. In-depth explanations of the most important aspects of international taxation take you step-by-step through these complex issues.

Each chapter includes numerous examples of companies working through real-life situations to enhance your practical understanding of the laws and regulations that govern international taxation.

Among many other topics, this book addresses:

  • U.S. international taxation rules, the latest planning techniques and legislative changes
  • Initiation of U.S. or foreign operations through a representative office, branch, incorporated subsidiary or joint venture, partnership or limited liability company
  • Transfer pricing, Subpart F, export incentive rules, U.S. trade or business effectively connected income and branch profits tax rules
  • Alternative means of capitalizing a U.S. or foreign start-up business
  • U.S. withholding tax requirements for fixed, determinable annual payments
  • How to work with foreign tax authorities and tax treaties, foreign bank accounts, international boycotts and currency transportation, including recently enacted FATCA and FBAR foreign ownership, reporting and withholding rules
  • U.S. foreign tax credit rules—determining whether foreign taxes are creditable, sourcing income and expenses and calculating the U.S. foreign tax credit limitation
  • Managing an overall foreign loss
  • Inbound and outbound international mergers, acquisitions and corporate transactions

As organizations from small to large go global, you can become the international tax expert you need to be.

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