This comprehensive Guide provides readers with a practical command of the basic concepts and issues surrounding U.S. taxation of international transactions, with an emphasis on essential areas that businesses and their financial advisors need to understand.

This fifth edition of the Practical Guide to U.S. Taxation of International Transactions has been completely revised to reflect the current state of U.S. international tax law after passage of the American Jobs Creation Act of 2004. It covers the repeal of the extra-territorial income (ETI) regime and its replacement by the domestic production deduction, the new temporary dividends-received deduction, modifications to the foreign tax credit, changes to the anti-deferral regimes, the tightening of tax rules on expatriation of individuals and more!

Topics include:

• Tax jurisdiction
• Source of income rules
• Foreign tax credit
• Transfer pricing
• Anti-avoidance provisions
• Governing foreign corporations
• Foreign sales corporations
• Foreign currency translation and transactions
• Tax treaties
• Planning of foreign operations
• Foreign persons investing in the U.S.
• Foreign persons doing business in the U.S.

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