Author Description

In 2017, the U.S. adopted the most far reaching changes to its international tax laws since 1962. This updated edition reflects these changes. The focus is on how the details of the tax law fit into a broader structure, which is described in the introduction. This book is divided into five parts. Part A addresses general problems such as jurisdiction to tax and the source rules for income and deductions. Part B deals with inbound tax issues. Part C is concerned with transfer pricing. Part D involves deferral and the foreign tax credit. Part E concludes by examining special topics like section 367 and the foreign exchange rules, and then discussing the relationship between the U.S. rules and the international tax regime, as embodied in the over 3,000 bilateral tax treaties. Part E also addresses some policy issues as to where international taxation may be headed in the 21st century, such as tax competition and tax arbitrage.