Now also available as
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
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
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
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.
Preface. 1. Introduction. 2. The US Income Tax System: General
Description. 3. Jurisdictional Principles. 4. Source Rules. 5.
Income Taxation of Nonresident Aliens and Foreign Corporations. 6.
Taxation of Foreign Source Income of US Persons: The Foreign Tax Credit. 7.
Treatment of Foreign Business Operations and Investments by US Persons. 8.
Transfer Pricing. 9. Special Treatment of Foreign Income. 10.
Foreign Currency Issues. 11. Income Tax Treaties. 12. Wealth