Significant Current Issues In International Taxation

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Multinational corporations face different tax systems in different countries that require careful tax planning. A systematic approach is needed to minimize and avoid unnecessary business taxes. Some core issues of international taxation are part of a successful corporate tax plan in an international context. The first issue is a good understanding and appreciation of the principles of international taxation that include the different philosophies of taxation, the different kinds of taxes, the different tax systems, the different tax treaties and potential tax havens. The second issue is a thorough understanding of U.S. taxation of foreign income to avoid double taxation and the computation of foreign tax credits. The third issue is the choice of a transfer pricing method and the compliance with tax regulations on both the transfer of tangible and intangible assets. The fourth issue is the intelligent use of tax vehicles for exporting which can generate substantial savings and reduce the effective tax rate and involve the choice between the interest-charge domestic international sales corporation and the foreign sales corporation. A final issue is the efficient use of value-added taxation for activities taking place outside the U.S., and a new appreciation of the potential of this form of taxation for the United States. Practicing accountants, academics, business executives, students, legislators, and others who want a better understanding of the complex issues of international taxation will be interested in this book.

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Editorial Reviews

Riahi-Belkaoui (accounting, U. of Illinois-Chicago) provides a guide to successful tax planning in a complex international context for foreign sales corporations, or more bluntly, to avoiding unnecessary taxation. Doing so requires a grasp of: the principles of international taxation, the US taxation of foreign income to avoid double tax jeopardy, transfer-pricing on asset transfer, savings- oriented tax vehicles for exporting, and issues of value-added taxation. Includes computations using alternative methods, current UK legislation, and foreign tax credit forms. Distributed in the US by Greenwood. Annotation c. by Book News, Inc., Portland, Or.
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Product Details

  • ISBN-13: 9781567201857
  • Publisher: ABC-CLIO, Incorporated
  • Publication date: 8/30/1998
  • Pages: 200
  • Product dimensions: 6.00 (w) x 9.00 (h) x 0.63 (d)

Meet the Author

AHMED RIAHI-BELKAOUI is CBA Distinguished Professor of Accounting in the College of Business Administration, University of Illinois at Chicago.

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Table of Contents

1 Principles of International Taxation 1
App. 1.A Current UK Legislation 24
App. 1.B Tax Policy and the Location of Plants and Profits 27
2 U.S. Taxation of Foreign Income 63
App. 2.A Form 1116, Foreign Tax Credit 81
App. 2.B Form 1118, Foreign Tax Credit - Corporations 83
App. 2.C Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations 89
3 Transfer Pricing 93
App. 3.A Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations 120
App. 3.B Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business 124
4 Tax Incentives for Exporting 129
App. 4.A Form 4876-A, Election To Be Treated as an Interest Charge DISC 151
App. 4.B Form 8279, Election To Be Treated as a FSC or as a Small FSC 153
App. 4.C Form 1120-FSC, U.S. Income Tax Return of a Foreign Sales Corporation 155
5 Value-Added Taxation 161
Index 181
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