Subjects:

Other Jurisdictions

Contents:

The US Income Tax System:

General Description.

Jurisdictional Principles.

Source Rules.

Income Taxation of Nonresident Aliens and Foreign Corporations.

Taxation of Foreign Source Income of US Persons:

The Foreign Tax Credit.

Treatment of Foreign Business Operations and Investments by US Persons.

Transfer Pricing.

Special Treatment of Foreign Income.

Foreign Currency Issues.

Income Tax Treaties.

Wealth Transfer Taxation.

Out Of Print

This edition, like previous editions, presents the basic principles and rules of the United States international tax system in a relatively brief and manageable form. The book provides a structural framework within which a US tax problem can be placed. As a general rule, tax practitioners outside the US whose clients have activities in the US will rely on their US tax advisors for technical advice on the US tax aspects of their clients' transactions.

However, the book is intended to enable foreign tax advisors to place the material they receive from their US counterpart in the overall structure of the US international tax system and thus be in a better position to evaluate the advice received and to relate it to their own tax systems.

The book is not intended as an exhaustive treatise that discusses in depth the wealth of technical detail involved in applying US tax rules in an international context. Instead, it provides an overview of the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad.

In line with these objectives, the book includes references to the Internal Revenue Code provisions under discussion and to the more important Treasury Regulations that are issued interpreting the statutory rules. In addition, the text contains significant administrative announcements of the Internal Revenue Service (Revenue Rulings and Revenue Procedures) as well as references to illustrative principal cases that have arisen.

Aware of the fact that not all readers have access to the reference materials cited in the footnotes, the authors have attempted to insure that the text discussion of a provision is self-contained so that the reader will be able to obtain a general understanding of the matter under discussion without resort to the footnote references. On the other hand, they did feel it important to provide sufficient reference materials so that the tax practitioner, professor or student would have a starting point to examine in greater technical detail the explanation offered in the text.