International Aspects of the US Taxation System
This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed
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International Aspects of the US Taxation System
Felix I. Lessambo
International Aspects of the US Taxation System
Felix I. Lessambo The Peter J. Tobin College of Business St. John’s University Jamaica, New York, USA
ISBN 978-1-349-94934-2 ISBN 978-1-349-94935-9 DOI 10.1057/978-1-349-94935-9
(eBook)
Library of Congress Control Number: 2016954153 © The Editor(s) (if applicable) and The Author(s) 2016 This work is subject to copyright. All rights are solely and exclusively licensed by the Publisher, whether the whole or part of the material is concerned, specifically the rights of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, express or implied, with respect to the material contained herein or for any errors or omissions that may have been made. Cover illustration: © Endai Huedl / Getty Printed on acid-free paper This Palgrave Macmillan imprint is published by Springer Nature The registered company is Nature America Inc. New York
ACKNOWLEDGEMENT
Writing a book is always a challenge. But writing a book on international aspects of the US tax system geared to MBA, MST students, and professionals, is an especially daring intellectual exercise for two reasons: the difficulty in choosing appropriate topics to cover and the complexity of each subject chosen. First and foremost, I would like to thank my wife, Aline, for standing beside me while writing this book and throughout my entire career. I would also like to express my gratitude to those who motivated me all along the project, knowing my dedication to the subject, and who believed in my ability to complete this project: James Thompson, Fouad Sayegh, and Brice Thionnet.
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CONTENTS
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Overview 1.1 Introduction 1.2 A Worldwide vs. Territorial Tax Regime 1.3 US Taxation of Individuals and Corporations 1.4 Reforming the US Tax System 1.4.1 Broadening the Tax Base 1.4.2 Integration of the Corporate and Individual Tax Systems 1.4.3 Taxing Certain Large Pass-throughs Notes
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The Underlying Principles of the US Tax System 2.1 Introduction 2.2 The Core Principles 2.2.1 Tax Neutrality 2.2.1.1 Capital Export Neutrality 2.2.1.2 Capital Import Neutrality 2.2.1.3 National Neutrality 2.2.1.4 Capital Ownership Neutrality 2.2.1.5 National Ownership Neutrality 2.2.1.6 Market Neutrality
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