U.S. estate and gift tax treaties /
" ... describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties to which the United States is a party, as well as the income tax treaty with Canada, which bears on U.S. transfer taxes as well as Canadian income tax at death. The portfolio is divided into...
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| Main Author: | |
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| Corporate Author: | |
| Format: | Online Continuing Resource |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management,
[©2003]-
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| Series: | Tax management portfolios ;
6896 |
| Subjects: | |
| Online Access: | https://www.bloomberglaw.com/product/tax/citation/tm%206896 |
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| Summary: | " ... describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties to which the United States is a party, as well as the income tax treaty with Canada, which bears on U.S. transfer taxes as well as Canadian income tax at death. The portfolio is divided into six parts. Part I: Introduction, explains the purpose and types of transfer tax treaties. Part II: Situs-Type Treaties, describes when situs-type transfer tax treaties apply and explains how a situs-type treaty assigns primary taxing jurisdiction to one country. It also analyzes the effect that situs-type treaties have on the deductions and credits of treaty countries. Part III: Domicile-Type Treaties, describes when domicile-type treaties apply and how these treaties assign primary taxing jurisdiction. It also analyzes the situs rules that are incorporated into domicile-type treaties, the effect that domicile-type treaties have on the deductions, exemptions, and credits of treaty countries, and the general operation of the treaties' nondiscrimination provisions. Part IV: Special, Administrative, and Enforcement Provisions, discusses the ways in which transfer tax treaties enable a treaty country to enforce the collection of death taxes and exchange information with the other country, as well as issues that a taxpayer subject to a treaty may face in reporting income. Part V: Treaty Interpretation, sets forth the principles of treaty interpretation and construction. Part VI: Particular Treaty Analysis, discusses the details of each transfer tax treaty." |
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| Item Description: | Published: Washington, D.C., 2003-2007 Published as Tax Management portfolio, 939, <Oct. 4, 2007>-2012 |
| Physical Description: | 1 online resource |
| Publication Frequency: | Updated irregularly |
| Format: | Mode of access: World Wide Web |
| Bibliography: | Includes bibliographical references |