international taxation concepts and insights

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This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Third Edition is divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.

This nutshell not only addresses the fundamentals of U.S. international taxation, but it also offers insight into tax planning considerations. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In the truly global economy in which we live, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. Building on both academic and private sector careers, the author has used his experience to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts, including the most recent developments.

The 2005 edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth 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. The presentation focuses on ten specific 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. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. The materials are current as of 1 January, 2005 and include a complete discussion of the changes made by the 2004 Jobs Creation Act . For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.

Previous edition, 2nd, published in 1990.

Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.

This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.

This study of taxation in Latin America takes a novel approach to the subject, using a framework that posits three dimensions for studying taxes—historical, relational, and transnational. The book argues that: first, taxation should be understood as a relational concept and tax systems as a function of a strategic nexus between the state and society; second, that any analysis of tax systems across Latin America needs to take historical legacies of national tax systems into account; and finally, that transnational phenomena have significant implications for tax regime dynamics in Latin America. The essays included provide diverse and representative insights for a new understanding of taxation in Latin America and highlight the bottlenecks to the development of sustainable tax systems in the region, exploring new links between academic research and policy-making.

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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