Intern. Applications Of U S Income Tax Law Inbound And Outbound Transactions by Ernest R.Larkins

Intern. Applications Of U S Income Tax Law Inbound And Outbound Transactions by Ernest R.Larkins

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A clear, concise explanation of United States tax law’s international aspects

In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes:

• Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate Also
• What a controlled foreign corporation is and what consequences result from this status Also
• Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles Also

International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Also

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Table of Contents

Preface.

PART ONE: Generic Topics.

CHAPTER 1: Policy and Overview.

International Tax Policy. Also

Entity Selection.

Generic Topics. Also

Inbound Transactions.

Outbound Transactions. Also

Related Person Transactions.

CHAPTER 2: Jurisdiction to Tax.

Tale of Two Systems. Also

U.S. Jurisdiction.

Double Taxation. Also

CHAPTER 3: Income Tax Treaties.

Treaty Creation and Authority.

Treaty Scope. Also

Personal Service Income.

Business Profit. Also

Investment Income.

Gain from Dispositions. Also

Special Clauses.

CHAPTER 4: Source of Income.

Fundamental Importance. Also

General Source Rules.

Interest Income. Also

Dividend Income.

Personal Service Income. Also

Rent and Royalty Income.

Gain from Selling Property. Also

Other Source Rules.

CHAPTER 5: Allocation and Apportionment.

Allocation to Classes. Also

Apportionment to Groupings.

Interest Deductions. Also

Research and Experimental Deductions.

Other Deductions. Also

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PART TWO: Inbound Transactions.

CHAPTER 6: Foreign Persons.

Residency Tests.

Counting Days. Also

Dual Status Aliens.

Important Elections. Also

CHAPTER 7: Nonbusiness Income.

Fixed or Determinable, Annual or Periodical Income.

Marginal Tax Rates. Also

Nonbusiness Exemptions.

Interest Stripping. Also

CHAPTER 8: Business Income.

U.S. Trade or Business.

Effectively Connected Income. Also

Business Exemptions.

Income Tax Calculations. Also

CHAPTER 9: Real Property Gains.

U.S. Real Property Interests.

U.S. Real Property Holding Corporations. Also

Withholding Procedures.

Structures for Holding U.S. Real Estate. Also

CHAPTER 10: Branch Taxes.

Branch Profits Tax.

Marginal Tax Rates. Also

Branch Interest Tax.

PART THREE: Outbound Transactions.

CHAPTER 11: Foreign Tax Credit.

Creditable Taxes. Also

Deemed Paid Taxes.

Limitation Formula. Also

Tax-Sparing Credit.

CHAPTER 12: Controlled Foreign Corporations.

CFCs and U.S. Shareholders.

Subpart F Income. Also

Earnings Invested in U.S. Property.

Constructive Dividends. Also

CHAPTER 13: Other Antideferral Provisions. Also

Passive Foreign Investment Companies.

Qualified Electing Funds. Also

Foreign Personal Holding Companies. Also

CHAPTER 14: Export Incentives.

Extraterritorial Income Exclusion. Also

Domestic International Sales Corporations.

CHAPTER 15: U.S. Individuals Abroad.

Foreign Earned Income Exclusion.

Income Sourced in U.S. Possessions. Also

Social Security Concerns.

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PART FOUR: Related Person Transactions. Also

CHAPTER 16: Transfer Prices.

General Principles. Also

Loan of Funds.

Performance of Services. Also

Rental of Tangible Property.

Sale or License of Intangible Property.

Sale of Tangible Property. Also

Valuation Misstatements. Also

Advance Pricing Agreements. Also

CHAPTER 17: Asset Transfers.

Outbound Asset Transfers.

Inbound Asset Transfers. Also

External Asset Transfers. Also

Glossary. Also

*Table of Statutes.

Table of Regulations. Also

*Table of Cases. Also

Table of Rulings. Also

Index.  Also

Author Information

Ernest R. Larkins is the E. Harold Stokes/KPMG Professor of Accounting at Georgia State University, where he teaches graduate courses in federal tax research and international taxation. Also He has published approximately 100 articles in various academic, law, and professional journals, as well as several chapters in books and monographs. Also He has received research fellowships from the Australian Taxation Studies Program (ATAX), University of New South Wales, and, for work conducted in Russia, the Society of International Business Fellows. He is an active member of the American Accounting Association and the American Taxation Association. Also

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