Us Taxation Of Foreign Income

This 2008 Supplement updates the four volume, International Taxation: U.S. Taxation of Foreign Persons and Foreign Income. The parent volume offers an all-inclusive, easy-to-follow discussion of the United States tax regime as applied to foreign transactions. It reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies that can be put to good use right away. The 2008 Supplement was authored by CCH Tax Law Editors.

Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

This book discusses basis principles (tax jurisdiction, source of income rules), U.S. taxation of foreign income (foreign tax credit, transfer pricing, anti-avoidance provisions governing foreign corporations, foreign sales corporations, foreign currency translation and transactions, tax treaties, planning of foreign operations) and U.S. taxation of foreign persons (foreign persons investing in the U.S. and foreign persons doing business in the U.S.).