Transfer pricing rules are an inescapable part of doing business internationally. This new editio... more Transfer pricing rules are an inescapable part of doing business internationally. This new edition of Practical Guide to U.S. Transfer Pricing is designed to help multinationals cope with the U.S. transfer pricing rules and procedures, taking into account the international norms established by the Organisation for Economic Co-operation and Development (the OECD ). It is also designed for use by tax administrators, both those belonging to the U.S. Internal Revenue Service and those belonging to the tax administrations of other countries, and tax professionals in and out of government, corporate executives, and their non-tax advisors, both American and foreign. The U.S. rules are presented along with ideas on how to apply them in a common-sense fashion in a multi-jurisdictional world
Selected Provisions and Analysis of the Tax Relief Act of 2010
The experts of Tax Facts have produced a comprehensive analysis of selected provisions of the Tax... more The experts of Tax Facts have produced a comprehensive analysis of selected provisions of the Tax Relief Act of 2010 to provide the most up to date information to their subscribers. The supplement analyzes important insurance, estate, gift, and other elements of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (H.R. 4853) as well as pertinent information on other important 2010 tax development
A case study examining the aspects of transfer pricing in relation to the highly integrated and o... more A case study examining the aspects of transfer pricing in relation to the highly integrated and opaque tobacco industry.This chapter presents a case study examining the aspects of transfer pricing in relation to the tobacco industry in Indonesia. The certain aspects include an identification of the supply chain of the tobacco industry, a value chain analysis of the industry, and the identification of transfer pricing indication.
The LexisNexis Guide to FATCA and CRS Compliance (LGFATC) provides a framework for meaningful int... more The LexisNexis Guide to FATCA and CRS Compliance (LGFATC) provides a framework for meaningful interactions among enterprise stakeholders, and between the FATCA Compliance Officer and the FATCA advisors/vendors. Analysis of the complicated regulations, recognition of overlapping complex regime and intergovernmental agreement requirements (e.g. Foreign Account Tax Compliance Act, Qualified Intermediary, source withholding, national and international information exchange, European Union tax information exchange, information confidentiality laws, money laundering prevention, risk management, and the application of an IGA) is balanced with substantive analysis and descriptive examples. The contributors hail from several countries and an offshore financial center and include attorneys, accountants, information technology engineers, and risk managers from large, medium and small firms and from large financial institutions. Thus, the challenges of the FATCA Compliance Officer are approached from several perspectives and contextual backgrounds. The Guide comprises 78 chapters covering topics including compliance programs, analysis of FATCA regulations and analysis of FATCA\u27s application for certain trading partners of the U.S., including intergovernmental agreements as well as the OECD\u27s TRACE initiative for global automatic information exchange protocols and systems
Nonresident Aliens and Foreign Corporations
Treatise Abstract: Provides in-depth analysis of the law of federal income taxation, explaining t... more Treatise Abstract: Provides in-depth analysis of the law of federal income taxation, explaining the intent of Congress in drafting the Code, what the Code means and how the Internal Revenue Service has been interpreting it. The book’s subject orientation rather than code orientation makes for easier understanding. The book’s discussions and analysis enables readers to find answers when no easy, clear-cut option is apparent
Taxation of Intellectual Property and Technology
Taxation of Intellectual Property and Technology fully integrates the latest legislative, adminis... more Taxation of Intellectual Property and Technology fully integrates the latest legislative, administrative, and judicial changes in the tax law as well as the patent, trademark, and copyright and trade secret laws. In addition, the book covers Internet taxation and international taxation. It is a comprehensive guide to the federal tax consequences of the development, purchase, sale and licensing of intellectual properties, including inventions (whether or not patentable), trade secrets, trademarks, trade names, copyrights, and computer software. Because of the highly transitory nature of the tax law and of the intellectual property law, rapid pace of technological development, especially the development of electronic commerce and the Internet, and the complex and often uncertain interplay between the two, Taxation of Intellectual Property and Technology is a must-have resource for intellectual property professionals, taxation professionals, and for general attorneys and accountants having some familiarity with either taxation or intellectual property
Walter H. Diamond and Dorothy B. Diamonds's three volume book, Tax-Free Trade Zones of the World,... more Walter H. Diamond and Dorothy B. Diamonds's three volume book, Tax-Free Trade Zones of the World, was published last by UNZ & Co. Inc. in 1998. Before Walter Diamond died, he asked me to reorganize, revise, and completely update that book. I agreed, and I have provided updates for each zone through 2010, wherever available. However, in this book I have focused on the zones and subzones in the United States. Zones in the rest of the world will be the subject of a future volume. 1 All fi gures and information relating to tax free trade zones are subject to change without notice.
Tax Havens of the World examines tax havens in more than 50 areas around the world and rates each... more Tax Havens of the World examines tax havens in more than 50 areas around the world and rates each on the basis of 30 vital features. Tax reform pitfalls are also analyzed. The publication gives you expert, inside information on how to: * Gain a foothold in a specific tax haven* Qualify for investment and capital incentives* Insulate profits* Plan a business or trust, including an asset protection trust* Examine types of exempt companies, offshore banking units, limited partnerships, and venture capital enterprises* Appraise economic and political risk factors* Know where to transfer funds for lowest withholding rates* Locate a trading company, captive insurance company, bank, or trus
Tax Facts on Investments
2016 Tax Facts on Investments provides clear, concise answers to often complex tax questions conc... more 2016 Tax Facts on Investments provides clear, concise answers to often complex tax questions concerning investments. Pertinent planning points are provided throughou
Patents, Franchises, Trademarks and Tradenames
Alimony and Divorce
For tax purposes, payments from one spouse to the other will be classified as alimony if they fit... more For tax purposes, payments from one spouse to the other will be classified as alimony if they fit within the tax code\u27s definition of alimony and separate maintenance payments under I.R.C. § 71 (hereinafter referred to as “alimony”). Such payments are classified as alimony regardless of the intent of the payor and payee spouses, unless the divorce or separation agreement specifies that the payment is not intended to be deductible alimony. Unlike most other classes of transactions-where the IRS often ignores the taxpayer\u27s characterization of a transaction in favor of the substance of the transaction-divorcing spouses have the ability to specify that a transaction otherwise satisfying the definition of alimony will not be treated as alimony for tax purposes. For any divorce or separation instrument executed before 2019, alimony payments are deductible by the payor spouse and included into income by the payee spouse; for any divorce or separation instrument executed after 2018, alimony payments are neither deductible by the payor nor includible in the income of the payee. The change is effective for any divorce or separation instrument executed after December 31, 2018, or for any divorce or separation instrument executed on or before December 31, 2018, and modified after that date, if the modification expressly provides that the amendments made by this amendment apply to the modification. There has been no change in the treatment of child support payments, which are not deductible or includible in income by the recipient. Further, property settlements are not alimony payments and are not deductible or includible in income. Rather, they are a division of property belonging to the parties
The OECD and the U.S. Regarding Risk Allocation
This subchapter explores the difference of review of risk allocation by contract between the Orga... more This subchapter explores the difference of review of risk allocation by contract between the Organization of Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Actions 8-10 revisions to the 2017 OECD Guidelines and the U.S. Tax Court in its decisions since 2010. The OECD and the U.S. Tax Court diverge in their adherence to the language of contracts as the basis for assessing and controlling risk allocation. On the one hand, the U.S. Tax Court following the prescription of the Internal Revenue Code has focused largely on contractual language and terms of agreement. On the other hand, the OECD analyzes actual economic behavior and reality, independent of the contractual language of the related parties. One of the changes to the 2017 OECD Guidelines initiated by BEPS in the Action Plan 8-10 is the interpretation of conduct in relation to reviewing the allocation of risk via a contractual arrangement between related parties, in particular with regards ...
Business Expenses: Deductible or Capitalizable
Deduction of Expenses for Production of Income
Tax Considerations for Real Estate Investments
Book Abstract: The Advisor’s Guide to Commercial Real Estate Investment is the only single volume... more Book Abstract: The Advisor’s Guide to Commercial Real Estate Investment is the only single volume A-Z guide to commercial real estate investment available today. It is an invaluable resource for anyone advising investors as well as for those seeking to increase their knowledge of real estate finance
Tax Facts on Individuals and Small Business
Tax Facts on Individuals & Small Business focuses exclusively on what individuals and small b... more Tax Facts on Individuals & Small Business focuses exclusively on what individuals and small businesses need to know to maximize opportunities under today’s often complex tax rules. It is the essential tax reference for financial advisors, & planners; insurance professionals; CPAs; attorneys; and other practitioners advising small businesses and individuals
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