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Synopsis
A Practical Guide to US Taxation of International Transactions provides the reader with a practical command of the basic concepts and issues surrounding US taxation of international transactions, with an emphasis on those areas of international taxation generally deemed to be essential to tax practitioners. This new edition has been completely updated to reflect important developments since the book was last published in 1998. Transfer pricing and tax treaties are given special attention in the revision and a new section on IRS procedure is offered. Also greatly enhanced is the discussion of choice of entities and the check-the-box regulations, certainly one of the hottest topics in US international tax.
Even with increased coverage, the book maintains its initial mission of providing a well-written and concise explanation of the subject that is accessible to all those who toil over US international tax issues.
The book is organized into three parts: Basic Principles, US Taxation of Foreign Income, and US Taxation of Foreign Persons, which discusses the following topics in detail: PART 1
- Tax Jurisdiction;
- Source of Income Rules; PART II
- Foreign Tax Credit;
- Transfer Pricing;
- Anti-Avoidance Provisions Governing Foreign Corporations;
- Foreign Sales Corporations;
- Foreign Currency Translation and Transactions;
- Tax Treaties;
- Planning of Foreign Operations; PART III
- Foreign Persons Investing in the United States;
- Foreign Persons Doing Business in the United States.
Appendices illustrate various applicable tax forms at the end of each Part. Also reproduced is the latest US Model Income Tax Treaty. This book is an indispensable reference guide for all those involved in international taxation.
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About the Author
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 pricing, and tax controversies. He previously worked as an attorney for the IRS seving with the IRS Chief Counsel (International) in Washington D.C. and as a large-case attorney in the Western and Southeast Regions. He also worked as a member of Deliotte & Touche's International Tax Services Group and has tried 23 cases before the U.S. Tax Court. He is a member of the Tax Section of the District of Columbia, California and Wisconsin Bars. He has written numerous articles on tax issues and has spoken at continuing education programs on tax as well. He is the author of CCH's "ETI Repeal Under the American Jobs Creation Act of 2004: Analysis of the Law's Impact on U.S. Business."
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