The Comparable Uncontrolled Price (CUP) method ensures arm's length pricing by comparing transactions between associated enterprises with comparable transactions between independent enterprises.
An in-depth examination of Controlled Foreign Corporations (CFCs), including definitions, historical context, key events, types, mathematical formulas, examples, and more.
A Double Taxation Agreement (DTA) is a treaty between two countries aimed at preventing the same income from being taxed in two jurisdictions. These agreements play a crucial role in facilitating international trade and investment by providing clarity on tax obligations for businesses and individuals.
Comprehensive coverage on policies aimed at reducing or eliminating double taxation, including tax treaties and credits.
An in-depth look into the concept of non-domiciled status, including its tax implications, historical context, key events, and much more.
Comprehensive exploration of Non-Resident Alien tax status, its implications, regulations, and more.
A comprehensive insight into the concept of Permanent Establishment (PE), its definition, types, examples, historical context, and related terms.
An Overview of the Remittance Basis of Taxation for Non-Domiciled Individuals in the UK
A detailed explanation of Residence-Based Taxation, a tax system where residents are taxed on their worldwide income.
Source-based taxation is a system where the tax jurisdiction is determined by the location where income or profits are generated.
A comprehensive look into Unilateral Relief, a measure by UK authorities to prevent double taxation for taxpayers with foreign income in countries without double-taxation agreements.
Comprehensive legislation that repeals the Foreign Sales Corporation/Extraterritorial Income regime, creates a new tax deduction for manufacturers, enhances small business expensing, and introduces numerous other changes affecting U.S. businesses and tax regulations.
Detailed explanation of Foreign Income, covering its definition, taxation, examples, and relevant regulations.
Detailed explanation of the Foreign Tax Credit, which allows U.S. taxpayers to offset foreign taxes paid against their U.S. income tax liability.
