United States Taxation of International Transactions Book

	Preface
	Acknowledgements
	Table of Cases
	Table of Internal Revenue Code Sections
	Table of Revenue Rulings and Procedures
	Table of Treasury Regulations
Ch. 1	Scope	1
Ch. 2	Introduction to Tax Treaties	30
Ch. 3	U.S. Taxation of the Personal Service Income of Nonresident Aliens	65
Ch. 4	U.S. Taxation of the U.S. Source Non-Trade or Business Income of Nonresident Aliens and Foreign Corporations	72
Ch. 5	Organizing and Operating a United States Business: Foreign Controlled U.S. Corporations, Branches, and Partnerships	113
Ch. 6	Sale or Liquidation of Foreign Controlled U.S. Corporation	181
Ch. 7	Taxable and Tax-Free Acquisitions of Domestic Corporations by Foreign Corporations	190
Ch. 8	Organization and Operation of Foreign Branches by U.S. Persons: Impact of Foreign Tax Credit, Sourcing Rules, and Foreign Currency Roles	223
Ch. 9	Organization of Foreign Corporations and Foreign Partnerships	348
Ch. 10	Treatment of Actual and Imputed Dividends to U.S. Corporate Shareholders of Foreign Corporations: The Indirect Foreign Tax Credit, Look Through Rules, Resourcing Rules, Dividends Received Deduction, and Foreign Currency Rules	373
Ch. 11	Section 482: Transactions Between Commonly Controlled Corporations	397
Ch. 12	Controlled Foreign Corporations	443
Ch. 13	Foreign Personal Holding Companies	521
Ch. 14	Passive Foreign Investment Companies	530
Ch. 15	The Foreign Sales Corporation	548
Ch. 16	Possessions Corporations	565
Ch. 17	Taxable Sale or Liquidation of a Foreign Corporation and Impact of Section 1248	580
Ch. 18	Tax-Free Acquisitions, Liquidations and Spinoffs of Foreign Corporations and Impact of Section 338 on Taxable Acquisitions of the Stock of Foreign Corporations	588
	Index	607