By Felix I. Lessambo
This publication covers a huge variety of the main difficult issues in US foreign taxation legislation prior to breaking into separate discussions of the problems with regards to either inbound and outbound taxes. genuine examples and chosen seminal circumstances are analysed on the finish of every bankruptcy to simplify even the main summary tax provisions. Practitioners, teachers, and complex scholars focusing on particular components of foreign finance will welcome this finished evaluate of the united states tax system's overseas laws.
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Extra info for International Aspects of the US Taxation System
Sample text
The special rule, however, permits portfolio investors in a REIT to be eligible for the 15-% maximum rate of withholding tax on dividends from the REIT. 1 A REMIC is not subject to US income tax. Instead, holders of a REMIC’s “residual interests” include in income their share of the REMIC’s net taxable income or loss each year. 2 For example, in a REMIC’s early years, payments of taxable interest received with respect to mortgage assets might be used to make nondeductible payments of principal with respect to a shorter-maturity regular interest.
REITs are specialized investments that pool the money of many investors to purchase real estate assets, primarily properties. REITs can focus on one property type, such as an office, or include many different kinds of property in a single portfolio. REITs can also vary in terms of their geographic focus—they can be regional, national, or global in scope. REITs and REMICs are generally not taxed on their real estate-related income or capital gain. Taxation usually occurs at the investor level. The special rule under the REIT aims to prevent a disparity between the taxation of direct real estate investments and real estate investments made INBOUND TAXATION 23 through REIT conduits.
This is a red herring: a graduated tax system is no more complicated than a flat-rate tax. 15 At the end of the day, adequacy is what separates successful tax systems from unsuccessful tax systems. Of course, at any given time, the primary concern for state lawmakers is short-term adequacy—making sure there’s enough revenue to fund public services in the upcoming fiscal year. But it’s equally vital for good-government advocates and lawmakers to seek strategies that will achieve long-term adequacy, balancing budgets not only this year and next but five years and ten years down the road.