Introduction to United States International Taxation, now in its seventh edition, is an outstanding reference work for the tax community that introduces the application of the United States (U.S.) international taxation system to taxpayers investing or transacting business in the U.S. and other countries. Clearly and concisely, it enumerates the principles adopted by the U.S. in taxing U.S. or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or overseas.
What’s in this book:
The compendium 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 accounting aspects;
- basic jurisdictional principles adopted by the U.S. concerning the application of its income tax to international investment and business transactions;
- the U.S. rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from U.S. sources;
- primary mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. persons;
- income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules;
- special treatment under FDII of a U.S. corporation’s export of goods, services and intangible rights;
- general intercompany pricing rules and special transfer pricing rules applicable to particular transactions;
- rules for the treatment of transactions involving currencies other than the U.S. dollar;
- situations in which U.S. income tax treaty provisions modify the basic rules; and
- wealth transfer tax system, including modifications made by estate and gift tax treaties.
The authors have extensively discussed and incorporated references to the Internal Revenue Code provisions under discussion, relevant Treasury Regulations and other administrative material and important cases that have arisen.
How this will help you:
This pragmatic book will prove to be an ideal reference source for non-U.S. tax practitioners, tax professors and students both within and outside the U.S., and others seeking a structural framework within which a U.S. tax problem can be placed.
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About the Authors
The United States Income Tax System: General Description
Income Taxation of Nonresident Aliens and Foreign Corporations
Treatment of Foreign Business Operations and Investments by US Persons
Formation, Reorganization, and Liquidation of Foreign Corporations: Section 367
Foreign Investment Activities by US Persons Utilizing Foreign Corporations
Taxation of Foreign Source Income of US Persons: The Foreign Tax Credit
Limitations on the Foreign Tax Credit
Special Treatment of Foreign Income
Foreign Currency Issues
Income Tax Treaties
Wealth Transfer Taxation