Practical Guide to U.S. Taxation of International Transactions (13th Edition)

Format: Print Book
Product ID: 10032341-0007
ISBN: 9780808058441
Expands on tax issues raised by international transactions and how those issues are resolved by U.S. tax laws.

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Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice.

The book is written primarily as a desk reference for tax practitioners and is organized into four parts:

Part I — Provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules.

Part II — Explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations.

Part III — Describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S. source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations.

Part IV — Covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

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More Information
Contributors Robert J. Misey, Michael S. Schadewald
Product Type Publications
ISBN 9780808058441
Format Print Book
Michael S. Schadewald
MICHAEL S. SCHADEWALD, PhD, CPA, Michael Schadewald, PhD, CPA, is a Clinical Professor in the Fisher School of Accounting at the University of Florida, where he teaches courses in accounting and taxation. A graduate of the University of Minnesota, Professor Schadewald co-authors the Multistate Corporate Tax Guide and the Practical Guide to U.S. Taxation of International Transactions, both published by Wolters Kluwer. Professor Schadewald has published over 60 articles in academic and professional journals, including The Accounting Review, Journal of Accounting Research, and Contemporary Accounting Research. He has also served on numerous editorial boards, including Journal of the American Taxation Association, International Tax Journal, Journal of State Taxation, and Issues in Accounting Education. Prior to joining the faculty at the University of Florida, Professor Schadewald taught at the University of Texas in Austin, as well as the University of Wisconsin-Milwaukee where he also served as the Director of the Deloitte Center for Multistate Taxation. Prior to entering academics, he worked in the Milwaukee office of Arthur Young (now EY).

Robert J.  Misey
Robert J. Misey
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment. For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts. Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm. Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system. Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.