Aspen Treatise for Introduction to United States International Taxation - Aspen Treatise

The new 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 U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.

The 7th Edition focuses on:

• General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects
• The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions
• The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources
• The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources
• The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules
• The special treatment under FDII of a U.S. corporation's export of goods, services, and intangible rights
• 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 U.S. dollar
• Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties