U.S. International Tax Forms Manual: Compliance and Reporting

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Practice Area: Treatises, International Brand: WG&L,Checkpoint

U.S. International Tax Forms Manual: Compliance and Reporting
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Everything required to comply with IRS disclosure and reporting at your fingertips.

Using more than 100 examples of transactions with completed sample IRS forms and commentary on what to do (and not do), U.S. International Tax Forms Manual prepares the international tax practitioner for IRS reporting and disclosure.

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Table of Contents

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Chapter 1: Direct Export of Goods
Chapter 2: Allocation and Apportionment of Corporate Deductions
Chapter 3: U.S. Foreign Tax Credit -- Basic Concepts
Chapter 4: U.S. Foreign Tax Credit -- Special Rules
Chapter 5: Initiation of Foreign Operations
Chapter 6: Foreign Branches and Affiliated Companies
Chapter 7: Indirect Sale or Use of Tangible Property
Chapter 8: Foreign Joint Ventures, Partnerships, and Limited Liability Companies
Chapter 9: Income and Expenditures of Related Parties
Chapter 10: Exploitation of Business Assets Outside the United States
Chapter 11: U.S. Possessions Corporations
Chapter 12: Foreign Transactions of Individuals
Chapter 13: Portfolio Investment in the United States
Chapter 14: Taxation of Foreign Businesses in the United States
Chapter 15: Foreign Business Financial Information
Chapter 16: Distributions to Foreign Shareholders
Chapter 17: Sample Forms

Appendix A. Revenue Procedure 91-22, 91-1 C.B. 526, promulgated March 18, 1991 Advance Pricing Agreement
Appendix B. Revenue Procedure 91-23, 91-1 C.B. 534, promulgated March 18, 1991 Competent Authority Assistance Request
Appendix C. Temporary Regulations Sections 1.482-1T--1.482-7T: Income From Controlled Transactions
Appendix D. Final Regulations Sections 1.482-1--1.482-8: Income From Controlled Transactions
Appendix E. Proposed Regulations Section 1.482-2: Determination of Taxable Income in Controlled Situations
Appendix F. Regulations Sections 1.6038A-0--1.6038A-7: Information, Record Maintenance, and Agent Authorization Rules for Foreign Corporations
Appendix G. Treasury Department's Model Income Tax Treaty of September 20, 1996
Appendix H. Treasury Department's Final Conduit Arrangements Regulations
Appendix I. Section 936 Profit-Split Method Regulations
Appendix J. Subpart F Foreign Personal Holding Company Regulations
Appendix K. Section 482 Cost-Sharing Regulations
Appendix L. Transfer Pricing Penalty Regulations
Appendix M. Revenue Procedure 97-27: Consent to Change Method of Accounting
Appendix N. Revenue Procedure 96-13: Assistance of U.S. Competent Authority Regarding Matters in Mutual Agreement Procedure Provisions of Tax Treaties
Appendix O. Final Check-The-Box Regulations
Appendix P. Foreign Tax Credit Substantiation Rules
Appendix Q. Revenue Procedure 2001-37: Foreign Trading Gross Receipts--Elections Under the FSC Repeal Act

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