United States International Taxation embodies two complementary goals: to provide tax students with a solid foundation in the applicable international tax rules and to enhance their skills in analyzing and applying complex statutes, regulations, and tax treaties. This fifth edition incorporates the tax law changes that have occurred since the publication of the fourth edition and also includes two new chapters that, from an inbound and outbound perspective, delve into the tax consequences attending cross-border partnership activities.
Consisting of 17 chapters, this casebook provides a streamlined discussion of the most important concepts of the international tax law in the United States, including:
- residency and sourcing of income;
- the taxation of United States persons (citizens, residents, and domestic corporations) on their activities abroad (outbound transactions);
- the taxation by statute and treaties of foreign persons (nonresident alien individuals and foreign corporations) on their activities within the United States (inbound transactions); and
- the rules in place to curtail potentially abusive tax deferral in the international context through the use of foreign corporations by United States persons (safeguard provisions).
As with prior editions, the fifth edition employs a problem-based approach. The model answers to these problems are set forth in an updated teacher's manual. Finally, given their importance in the international arena, the casebook addresses the role of tax treaties and includes in the appendix a reprint of the United States-Canada Tax Treaty and the Treasury Department's technical explanations of the various protocols thereof.