United States International Taxation
LexisNexis, Jan 19, 2011 - Law - 648 pages
This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross-border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.
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50 percent activities alien allocation amount apply arm’s-length assets attributable basket benefits business profits Canadian capital gain CBS Records competent authorities Contracting Convention corporation’s cost deduction deemed determining discussed in Unit distribution dividends domestic corporation double taxation earnings and profits effectively connected election employee enterprise entity example exempt expenses foreign corporation foreign country foreign person foreign sales corporation foreign source foreign tax credit foreign taxes paid gross income imposed individual individual’s intangible intangible asset interest investment item of income jurisdiction limitation nonresident alien OECD ownership partnership passive income payment pension permanent establishment petitioner PFIC presence test Protocol provides qualifying real property Regulation respect Revenue Ruling Roth IRA royalties source income source rules subparagraph subsidiary tax purposes tax rate tax treaty taxable income taxpayer trade or business transactions transfer United States person United States source United States tax USCo withholding tax