International Taxation, 6th (Concepts and Insights Series)

Preliminary Sections

• Preliminary Sections
• Preface

Preface

• Preliminary Sections
• Preface

Part I. Common Issues For Both Inbound and Outbound U.S. Taxation

• U.S. Taxation in the International Setting
• Nationality and Residence for Taxation
• The Source of Income
• International Transfer Pricing

Part II. Inbound U.S. Taxation

• U.S. Taxation of Foreign Persons: Fixed and Determinable Income
• U.S. Taxation of Foreign Persons: Taxation of a Trade or Business
• Income Tax Treaties
• Inbound Base Protection Measures That Backstop Inbound Taxation

Part III. Outbound U.S. Taxation

• Outbound Taxation in Overview
• Direct Foreign Investment: The Foreign Tax Credit Regime
• Controlled Foreign Corporations
• Passive Foreign Investment Companies (PFICs)
• Dispositions, Liquidations, and Reorganizations of Controlled Foreign Corporations and Incorporations of Foreign Branches
• Miscellaneous Foreign Incentives Regimes
• Table of cases