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International applications of U.S. income tax law : inbound and outbound transactions / Ernest R. Larkins.

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International Applications of U.S. Income Tax Law provides tax, accounting, and legal practitioners in the U.S. with a fundamental understanding of major concepts and issues in international tax. Readers willbecome more knowledgeable ofhow taxpayersachieve excess credit or excess limit positions and...

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Bibliographic Details
Online Access: Full Text (via EBSCO)
Main Author: Larkins, Ernest R. (Ernest Radford)
Other title:International applications of US income tax law.
Format: eBook
Language:English
Published: Hoboken, N.J. : John Wiley & Sons, ©2004.
Subjects:
Noncitizens.
Income tax > United States > Foreign income.
Investments, Foreign > Taxation > Law and legislation > United States.
Noncitizens > Taxation > Law and legislation > United States.
Foreign tax credit > United States.
Double taxation > United States.
Double taxation.
Foreign tax credit.
Income tax > Foreign income.
Investments, Foreign > Taxation > Law and legislation.
United States.
Undocumented immigrants.
Table of Contents:
  • Policy and overview
  • Jurisdiction to tax
  • Income tax treaties
  • Source of income
  • Allocation and apportionment
  • Foreign persons
  • Nonbusiness income
  • Business income
  • Real property gains
  • Branch taxes
  • Foreign tax credit
  • Controlled foreign corporations
  • Other anti-deferral provisions
  • Expert incentives
  • U.S. individuals abroad
  • Transfer prices
  • Asset transfers.

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