This casebook provides detailed information on federal wealth transfer taxation. The casebook provides the tools for fast, easy, on-point research. Part of the University Casebook Series®, it includes selected cases designed to illustrate the development of a body of law on a particular subject. Text and explanatory materials designed for law study accompany the cases.

Federal Wealth Transfer Taxation: Cases and Materials (University Casebook Series)

James R. Repetti

Paul L. Caron

Paul R. McDaniel

Administrative Law

Foundation Pr

This handbook examines partnership tax laws, enabling readers to easily understand specific provisions within a larger context. Some of the topics covered include what constitutes a partnership; partnerships vs. corporations; partnership vs. co-ownership of property; the pass-through principle of partnership taxation; an introduction to partnership debt; allocations of partnership income; transactions between partnerships and their partners; sales of partnership interests; partnership distributions; payments to retiring partners; and the death of a partner.

Partnership Income Taxation

Business & Money

Alan Gunn

Accounting

The 2005 edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on ten specific aspects of the subject matter:    general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts and estates, and accounting aspects;   the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions;   the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources;   the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons;   the income tax treatment of foreign corporations controlled by US shareholders;   the general inter-company pricing rules and special transfer pricing rules applicable to particular transactions;   rules for the treatment of transactions involving currencies other than the US dollar;   situations in which US income tax treaty provisions modify the basic rules; and   the wealth transfer tax system, including modifications made by estate and gift tax treaties.    Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act .   For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.

Introduction to United States International Taxation, Revised 5th Edition

Hugh Ault

Foreign & International Law

Aspen Publishers

The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: <ul> <li>general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects;</li> <li>the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions;</li> <li>the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources;</li> <li>the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons;</li> <li>the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules;</li> <li>the special treatment under FDII of a US corporation's export of goods, services and intangible rights;</li> <li>the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions;</li> <li>rules for the treatment of transactions involving currencies other than the US dollar;</li> <li>situations in which US income tax treaty provisions modify the basic rules; and</li> <li>the wealth transfer tax system, including modifications made by estate and gift tax treaties.</li> </ul> Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source. &nbsp;

Introduction to United States International Taxation

Diane M. Ring

Stephen Shay

Finance

Kluwer Law International

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Books by James R. Repetti