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U.S. Taxation of Foreign-Controlled Businesses offers the advice and counsel necessary to make a sound assessment of the unique tax, legal and financial issues facing non-U.S. businesses operating in the United States.
Refer to summary discussions of the tax systems in France, UK, Japan, Germany, Canada, Mexico and the Netherlands, written by practitioners in the respective countries to better size the tax implications of doing business in each of these countries.
Become better informed on how to handle tax treaty issues; create effective and sound transfer pricing plans; and structure an investor's entry into the U.S. This treatise covers many other key taxation consequences of operating a foreign-controlled business in the U.S.
You'll see how to:
- Effectively handle tax treaty issues and planning
- Navigate the maze of transfer pricing rules and negotiate effective advance pricing agreements
- Balance a company's customs planning with its transfer pricing policy
- Determine whether an existing tax treaty provides any relief for a given transaction
- Use transfer pricing methods that minimize tax liability yet meet strict IRS standards
- Comply with all reporting and disclosure requirements--and avoid substantial penalties
- Select the best structure for an investor's entry into the U.S.
- Deal with key foreign tax laws
Subscription includes International Taxes Weekly, a weekly electronic newsletter providing coverage of all major international tax developments.
- Levey: U.S. Taxation of Foreign-Controlled Businesses
- Chapter 1: Overview of U.S. Taxation of Foreign Taxpayers Doing Business in the United States
- Chapter 2: Structural Issues—Considerations in Forming a Structure and Selecting an Entity to Engage in Business
- Chapter 3: Tax Treaty Planning
- Chapter 4: Acquisition of U.S. Operations
- Chapter 5: Financing the U.S. Operation
- Chapter 6: Earnings Stripping
- Chapter 7: Transfer Pricing
- Chapter 8: Economics in Establishing a Sound Transfer Pricing Policy
- Chapter 9: Customs Issues for Imported Goods
- Chapter 10: Antidumping and Countervailing Duties
- Chapter 11: U.S. Taxation of Intangible Property
- Chapter 12: Reporting and Disclosure Requirements for Foreign Held Companies
- Chapter 13: State and Local Tax Aspects of International Investment
- Chapter 14: Foreign Investment in U.S. Real Estate
- Chapter 15: Preimmigration Planning for Executives of Foreign Corporations
- Chapter 16: Avoiding and Resolving International Tax Disputes
- Chapter 17: Withholding Obligations for Nonresident Aliens
- Chapter 18: Foreign Tax Considerations for U.S. Investments