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Essentials of United States Taxation

Essentials of United States Taxation

By Howard E. Abrams, Richard L. Doernberg


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Where there's trade, there's taxation. And more often than not these days, that means United States taxation.

Essentials of United States Taxation clearly explains basic structural features and accounting issues, corporate and partnership taxation, and the rules governing international transactions, both inbound and outbound. It provides concise, accurate answers to such questions as:

  • What is the US tax treatment of mergers and acquisitions?
  • How are joint ventures and other hybrid entities taxed in the United States?
  • How does the US foreign tax credit work?
  • What are the most tax-beneficial ways to form a business in the United States?
  • How can special profit and loss allocations under US partnership law be used in international transactions?

    The only easily readable overview of the subject available, this book is useful in two different ways. Reading it cover to cover provides a crystal-clear `picture' of the US tax system, yet the book is also of great value as a quick reference when a US tax problem needs to be solved. Numerous real-life examples make specific provisions of the US tax system easily understandable even to readers with no background in the subject.

  • Publish Date 07/01/1999
    Publish Frequency As Needed
    Product Line Kluwer Law International
    ISBN 9789041109644
    SKU 10057722-0001
    Table of Contents
    1. General Principles.
      Overview of Taxation in the United States.
      Federal Income Taxation: Structural Issues.
      Federal Income Tax: Conceptual Issues.
      Legislative, Administrative and Judicial Aspects.
    2. Corporate Taxation.
      The Corporate Double Tax.
      Forming a Corporation.
      The Corporation as a Taxable Entity.
      Cash and Property Distributions.
      Stock Dividends.
      Tainted Stock.
      Taxable Acquisitions.
      Combining Tax Attributes.
      Penalty Provisions.
      S Corporations.
    3. Partnership Taxation.
      The Structure of Partnership Taxation.
      Determining Distributive Shares.
      A Partner's Outside Basis.
      Nonliquidating Distributions.
      A Partner's Transactions with the Partnership.
      Acquisitions of Partnership Interests. Dispositions of Partnership Interests.
      Loss Limitations.
      Optional Basis Adjustments.
      Partnership-Level Issues.
    4. International Taxation.
      Basic U.S. Jurisdictional Tax Principles.
      Taxing Rules.
      Source Rules.
      The Role of Income Tax Treaties.
      Filing, Withholding, and Reporting Requirements.
      Introduction to U.S. Business Activity in Foreign Countries.
      The Foreign Tax Credit.
      Intercompany Pricing.
      Controlled Foreign Corporations and Related Provisions.
      Foreign Currency. International Tax-Free Transactions.
      Tax Arbitrage and Economic Substance. Foreign Sales Corporations.
      International Boycott and Foreign Bribery Provisions.
      Estate and Gift Taxation for Resident and Nonresident Aliens.