Practical Guide to U.S. Taxation of International Transactions (Sixth Edition 2007)Topics and Contents |
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| PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME |
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| Overview of U.S. Taxation of International Transactions |
| Tax Jurisdiction |
| Source of Income Rules |
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| PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS |
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| Foreign Tax Credit |
| Deemed Paid Foreign Tax Credit |
| Anti-Deferral Provisions |
| Foreign Currency Translation and Transactions |
| Export Benefits |
| Planning for Foreign Operations |
| State Taxation of Foreign Operations |
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| PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS |
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| Foreign Persons Investing in the United States |
| Foreign Persons Doing Business in the United States |
| Planning for Foreign-Owned U.S. Operations |
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| PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS |
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| Transfer Pricing |
| Income Tax Treaties |
| Cross-Border Transfers and Reorganizations |
| International Tax Practice and Procedure |