International Taxation in a Nutshell Book

Preface

Table of Cases

Table of Internal Revenue Code Sections

Table of Treasury Regulations and Revenue Rulings

PART ONE OVERVIEW OF FUNDAMENTAL CONCEPTS

1. Introduction

2. Basic U.s. Jurisdictional Tax Principles

PART TWO U.S. ACTIVITIES OF FOREIGN TAXPAYERS

3. Taxing Rules

4. Source Rules

5. The Role of Income Tax Treaties

6. Introduction to U.s. Business Activity in Foreign Countries

7. The Foreign Tax Credit

8. Intercompany Pricing

9. Controlled Foreign Corporations and Related Provisions

10. Foreign Currency

11. International Tax-Free Transactions

PART FOUR SPECIAL INCENTIVES AND DISINCENTIVES

12. Foreign Sales Corporations

13. International Boycott and Foreign Bribery Provisions

PART FIVE UNITED STATES TRANSFER TAX PROVISIONS

14. Estate and Gift Taxation for Resident and Nonresident Aliens