Basic rules of U.S. taxation for inbound foreign investment: ALI-ABA course of study materials
American Law Institute-American Bar Association Committee on Continuing Professional Education, Georgetown University. Law Center, National Foreign Trade Council
American Law Institute-American Bar Association Committee on Continuing Professional Education, 1991 - Business & Economics - 362 pages
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DISCLOSURE AND INFORMATION REPORTING
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activities adjustments Advance Pricing Agreements agreement allocation amount apply arm's length attributable branch profits tax branch tax cost sharing arrangement deduction deemed determined distribution dividends domestic corporation ECE&P election estate tax excess interest exemption foreign corporation foreign parent foreign person foreign tax gain gift tax inbound income tax treaty intangible property interest paid investment investor issues liabilities multinational Netherlands Antilles nonresident alien NPTs operating partnership payments permanent establishment prior procedure provides qualified resident real property interest related parties royalty rules section 482 shareholders stocks or securities subject to U.S. taxable taxpayer Temp Temporary Regulations tion trade or business transactions transfer pricing Treas treaty benefits treaty country treaty overrides U. S. citizen U.S. assets U.S. branch U.S. business U.S. corporation U.S. net equity U.S. person U.S. real property U.S. subsidiary U.S. tax U.S. trade withholding tax