Chapters 1 & 2 - MULTIJURISDICTIONAL TAXATION...

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MULTI-JURISDICTIONAL  TAXATION OVERVIEW AND TAX  JURISDICTION
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OVERVEIW Types of Government Tax Systems Credit System (Worldwide Income Taxation – U.S.) Territorial (Domestic Income Taxation and Value Added Taxes – Europe) U.S. Taxation of Foreign Income Taxed at U.S. Rate Foreign Taxes Deducted as a credit Direct Foreign Tax Credit (amounts actually paid) Deemed Foreign Tax Credit (gross up for dividends received) Provides equivalent treatment for remittances from branches or subsidiaries
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OVERVIEW When is foreign income taxed Branch (when earned) Subsidiary (when remitted) Exception for Subpart F Income (anti- avoidance rules) How is income measured Foreign Currency Translation Rules Transfer Pricing Rules Relief Tax Treaties
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OVERVIEW Taxation Foreign Person’s U.S. Activities Resident Alien (U.S. Tax Rules) vs. Nonresident Alien Status (Special Reduced Tax Rates) Investment Activities (30% Flat Rate) U.S. Withholding Required Business Activities (Graduated Tax Rates)
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