Concepts and insights series. Study aids (West Academic Publishing)
Bibliography, etc. Note
Includes bibliographical references and index.
Formatted Contents Note
U.S. taxation in the international setting Nationality and residence for taxation The source of income International transfer pricing U.S. taxation of foreign persons: passive investment income the meaning of a U.S. "trade or business" "Effectively connected" income Gains from sales of U.S. real property The branch profits tax Outbound taxation in overview The foreign tax credit: background and overview The foreign tax credit: creditable foreign taxes The credit limitation of section 904 The indirect foreign tax credit Grand overview of dividends from foreign corporations Controlled foreign corporations: subpart F Controlled foreign corporations: section 1248 Passive Foreign Investment Companies (PFICs) International corporate reorganizations U.S. citizens abroad Income tax incentives for exports Income tax treaties in overview Residence in income tax treaties Business profits: permanent establishments Compensation for personal services Interest, dividends, royalties, rents, and other gains The rise and fall of treaty tax shelters: sandwiches, conduits, and the treasury's response.
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Description based on e-publication title page, viewed December 19, 2017.