Maglione, Gaia (A.A. 2022/2023) Doing business in the United States: main tax ramifications for Italian corporate investors entering the foreign market. Tesi di Laurea in International and European taxation, Luiss Guido Carli, relatore Andrea Silvestri, pp. 112. [Single Cycle Master's Degree Thesis]

Full text for this thesis not available from the repository.

Abstract/Index

Fundamental concepts of international taxation. Birth and fundamentals of international tax law. Boundaries of a State’s taxing power. The concept of international double taxation. Foreign direct investment and the factors affecting investors’ tax burden. Introduction to the case s: ItaCo. Permanent establishment. PE definition: the US “carrying on a trade or business” concept. Allocation of business profits to the US permanent establishment. Can the activities carried our in the US be considered as a US permanent establishment of ItaCo? Subsidiary: US corporation and LLC. Hints on US Corporate Law: The “check-the-box” regulations. C corporation: analysis of Its legal aspects and determination of the tax regime in cross-border operations. The advent of limited liability companies and the reason of their Success. Exit from the direct investment in the United States. Definition and tax treatment of capital gains from shares under US and Italian domestic law. Capital gains under the Italy-US double tax treaty.

References

Bibliografia: pp. 102-112.

Thesis Type:	Single Cycle Master's Degree Thesis
Institution:	Luiss Guido Carli
Degree Program:	Single Cycle Master's Degree Programs > Single Cycle Master's Degree Program in Law (LMG-01)
Chair:	International and European taxation
Thesis Supervisor:	Silvestri, Andrea
Thesis Co-Supervisor:	Rasi, Federico
Academic Year:	2022/2023
Session:	Summer
Deposited by:	Alessandro Perfetti
Date Deposited:	05 Dec 2023 13:56
Last Modified:	05 Dec 2023 13:56
URI:	https://tesi.luiss.it/id/eprint/37221

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