International Taxation in a Nutshell » (8th Edition)

This 5x7.5" reference serves as an introduction to the US law of international taxation for law students, foreign lawyers, and US lawyers seeking an introduction or refresher. It overviews US tax laws governing international trade and investment, making frequent reference to the International Revenue Code and the Income Tax Regulations. Sections cover fundamentals of US international taxation, the US activities of foreign taxpayers, foreign activities of US citizens and residents, special US international tax provisions creating incentives and disincentives for certain conduct or transactions, and the effect of US transfer taxes on resident and nonresident aliens.

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Table of Cases

Table of Internal Revenue Code Sections

Table of Treasury Regulations and Revenue Rulings

PART ONE OVERVIEW OF FUNDAMENTAL CONCEPTS

1. Introduction

2. Basic U.s. Jurisdictional Tax Principles

PART TWO U.S. ACTIVITIES OF FOREIGN TAXPAYERS

3. Taxing Rules

4. Source Rules

5. The Role of Income Tax Treaties

6. Introduction to U.s. Business Activity in Foreign Countries

7. The Foreign Tax Credit

8. Intercompany Pricing

9. Controlled Foreign Corporations and Related Provisions

10. Foreign Currency

11. International Tax-Free Transactions

PART FOUR SPECIAL INCENTIVES AND DISINCENTIVES

12. Foreign Sales Corporations

13. International Boycott and Foreign Bribery Provisions

PART FIVE UNITED STATES TRANSFER TAX PROVISIONS

14. Estate and Gift Taxation for Resident and Nonresident Aliens