Introduction To United States International Taxation, 6th Edition
The presentation focuses on the following aspects of the subject matter:
- general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts and estates, and accounting aspects;
- the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions;
- the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources;
- the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons;
- the income tax treatment of foreign corporations controlled by US shareholders;
- the general inter-company pricing rules and special transfer pricing rules applicable to particular transactions;
- rules for the treatment of transactions involving currencies other than the US dollar;
- situations in which US income tax treaty provisions modify the basic rules; and
- the wealth transfer tax system, including modifications made by estate and gift tax treaties.
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About the Authors.
Chapter 1 Introduction.
Chapter 2 The United States Income Tax System: General Description.
Chapter 3 Jurisdictional Principles.
Chapter 4 Source Rules.
Chapter 5 Income Taxation of Nonresident Aliens and Foreign Corporations.
Chapter 6 Taxation of Foreign Source Income of United States Persons: The Foreign Tax Credit.
Chapter 7 Treatment of Foreign Business Operations and Investments by United States Persons.
Chapter 8 Transfer Pricing.
Chapter 9 Special Treatment of Foreign Income.
Chapter 10 Foreign Currency Issues.
Chapter 11 Income Tax Treaties.
Chapter 12 Wealth Transfer Taxation.