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Jurisdiction to Tax Tx 8300

Jurisdiction to Tax Tx 8300. Learning Objectives. You should be able to:. Describe and distinguish the ___ types of jurisdictions, Explain jurisdiction under ___ tax system, and Know the importance of ____________ decisions. Jurisdiction Defined. Power of ___________ to impose tax

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Jurisdiction to Tax Tx 8300

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  1. Jurisdiction to TaxTx 8300

  2. Learning Objectives You should be able to: • Describe and distinguish the ___ types of jurisdictions, • Explain jurisdiction under ___ tax system, and • Know the importance of ____________ decisions

  3. Jurisdiction Defined • Power of ___________ to impose tax • Analogous to _____ in SALT

  4. General Concepts Jurisdiction OverBasis of Taxation Parties a. b. c. d. a. Transactions b.

  5. Around the World Global Systems Territorial Systems Bolivia Costa Rica France Guatemala Malaysia Panama Uruguay Brazil Germany India Mexico United Kingdom United States

  6. Double Tax Problems • Two countries claim same ______ as resident • Two countries claim jurisdiction over same ___________ • One country claims jurisdiction over ______ while second country claims jurisdiction over ___________ • Absent some fix, what is the result?

  7. Mitigating Double Tax UnilaterallyBilaterally a. _________ method a. Commonly defined _______ b. Tax ______ b. Common ______ rules c. _________ method d. _________ tax rates e. _________ authority

  8. U.S. Tax System • Nonresident aliens and foreign corporations • ___ source investment income • ____________ connected income • U.S. citizens, residents, and corporations • _________ income • Foreign tax ______

  9. U.S. Jurisdiction Illustrated DC FC Does the U.S. tax the DC on its foreign profit? Does the U.S. tax the FC on its ECI?

  10. Check the Box • Only ________ ________ can select tax classification. • Trade, business, or venture • Carried on • To earn and ______ profits • “___ __” corporations • Always treated as ________ corporations • Includes __ foreign _____ ______ companies

  11. Check the Box • Single-owner foreign business entities • Treated as _________ or branch • If owner has (no) ______ ______ under _____ law, default classification is corporation (______) • Multiple-owner foreign business entities • Treated as corporation or __________ • If all owners (do not) have ______ ______ under _____ law, default classification is corporation (______)

  12. Hybrid Entities • Example • Host country treats as ___________ • U.S. treats as ______ • Advantages • _______ ________ in host country • Flow-through of _____-__ ______ • Easier flow-through of _______ ___ _______

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