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9780314188069

Global Issues in Income Taxation

by
  • ISBN13:

    9780314188069

  • ISBN10:

    0314188061

  • Edition: 1st
  • Format: Paperback
  • Copyright: 2008-05-06
  • Publisher: West Academic Publishing

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Supplemental Materials

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Summary

This concise book is designed to provide professors teaching an introductory federal income taxation course with supplementary materials to introduce students to comparative and international tax topics. The book is accessible to students early in the course. An introductory chapter covers the structure of global tax systems and income taxes, as well as the various concepts of "income" employed by different tax systems. Coverage also includes chapters exploring the comparative tax treatment of in-kind benefits, gifts and inheritances, deductions, the taxable unit and income splitting rules, and capital gains. A separate chapter explores the issues raised when income is earned in international transactions. Basic international tax coverage includes an introduction to taxation based on source or residence/citizenship, avoidance of double taxation, tax deferral, transfer pricing, and tax treaties. The book includes both domestic and foreign cases, authorities, and statutes, as well as explanatory text. Because of its coverage, this text also is an excellent vehicle for exploring tax policy issues.

Author Biography

Daniel Lathrope, Professor of Law, University of California, Hastings College of the Law

Table of Contents

Prefacep. v
Table of Casesp. xv
Introduction to Global Tax Systems and Income Taxesp. 1
Introductionp. 1
The Structure of Income Taxesp. 4
The Nature of "Income"p. 6
Commissioner of Taxation v. Cooke & Sherdenp. 8
Benefits in Kindp. 18
Introductionp. 18
Excerpt From the Report of the Royal Commission on Taxationp. 18
Notep. 20
Detchon v. Her Majesty the Queenp. 20
Guay v. Her Majesty the Queenp. 27
Notep. 32
Taxation of Fringe Benefitsp. 32
Ruling 1999/6p. 34
Notep. 39
Gifts and Inheritancesp. 43
Introductionp. 43
Campbell v. Minister of National Revenuep. 44
McMillan v. Minister of National Revenuep. 49
Notep. 51
Gifts as Realization Eventsp. 52
Notep. 53
The Queen v. Mastronardip. 56
Taxable Unit and Attribution of Incomep. 59
The Taxable Unitp. 59
Family Allowancesp. 62
Income Splitting Rulesp. 62
Income Attribution in Canadap. 63
Assignments Without the Transfer of Propertyp. 64
It-335R2p. 65
Notep. 68
Neuman v. Minister of National Revenuep. 69
Notep. 79
Overton v. Commissionerp. 80
Notep. 81
Ferrel v. Her Majesty the Queenp. 82
Notep. 90
Attribution of Income, Gain, or Loss in Connection With the Transfer of Propertyp. 91
Deductionsp. 97
Introductionp. 97
General Rules for Australian Tax Deductionsp. 99
Federal Commissioner of Taxation v. Snowden & Willson Proprietary Ltd.p. 100
Softwood Pulp & Paper Ltd v. Commissioner of Taxationp. 104
Notep. 108
Interpretive Decision 2006/614p. 109
Morris v. Commissioner of Taxationp. 110
Case 29/95p. 124
Notep. 126
Charitable Deductions in Australiap. 126
Interpretive Decision 2003/727p. 126
Interpretive Decision 2002/577p. 129
French Decisionsp. 130
Case N. 35 697p. 130
Notep. 131
Decision of French Constitutional Councilp. 131
Notep. 136
Taxation of Capital Gains and Lossesp. 137
Introductionp. 137
The Californian Copper Syndicate v. The Inland Revenuep. 137
Merchants' Loan & Trust Co. v. Smetankap. 140
Notep. 145
Policyp. 146
Blueprints for Basic Tax Reformp. 147
Notep. 151
The Tax Treatment of Capital Gains in Foreign Jurisdictionsp. 151
Notep. 153
Income Tax Interpretation 120R6p. 154
Notep. 159
Restrictions on Capital Lossesp. 159
International Income Taxationp. 161
Introductionp. 161
Cook v. Taitp. 161
Notep. 164
An Overview of United States International Taxationp. 165
Revenue Ruling 69-630p. 170
Notep. 171
Johansson v. United Statesp. 172
Simenon v. Commissionerp. 176
International Taxation in Foreign Tax Systemsp. 180
Excerpt From the Impact of International Tax Reform: Background and Selected Issues Relating to U.S. International Tax Rules and the Competitiveness of U.S. Business pp. 32-54p. 180
Indexp. 197
Table of Contents provided by Ingram. All Rights Reserved.

Supplemental Materials

What is included with this book?

The New copy of this book will include any supplemental materials advertised. Please check the title of the book to determine if it should include any access cards, study guides, lab manuals, CDs, etc.

The Used, Rental and eBook copies of this book are not guaranteed to include any supplemental materials. Typically, only the book itself is included. This is true even if the title states it includes any access cards, study guides, lab manuals, CDs, etc.

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