U.S. International Taxation: Practice and Procedure

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Practice Area: Treatises, International Brand: Checkpoint

U.S. International Taxation: Practice and Procedure
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Transaction–oriented presentation of all procedural matters.

U.S. International Taxation: Practice and Procedure is a complete procedural resource that provides step-by-step guidance for handling all IRS issues relating to documentation, compliance and controversy for all international tax issues. The presentation is transactional in orientation, supported by fact patterns.

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Table of Contents

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Chapter 1: Introduction and Scope
Chapter 2: Returns and Statutes of Limitations
Chapter 3: Taxpayer Documentation Requirements and Penalties
Chapter 4: IRS Information Gathering Procedures
Chapter 5: IRS Examination of International Transactions
Chapter 6: IRS Appeals Office Procedures
Chapter 7: U.S. Withholding Tax Procedures
Chapter 8: Preparation of Taxpayer Position
Chapter 9: Treaty Procedural Matters
Chapter 10: IRS Ruling Procedures
Chapter 11: Advance Pricing Agreement Procedures
Chapter 12: Alternative Dispute Resolution Procedures
Chapter 13: Tax Litigation
Chapter 14: Financial Accounting and Taxation

Appendix I. Internal Revenue Manual: International Taxation Materials

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