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United States International Taxation (2 Volumes): Outbound and Inbound Activities

Name: United States International Taxation (2 Volumes): Outbound and Inbound Activities
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Book Synopsis: Replete with hundreds of charts and illustrations, this two-volume treatise provides an in-depth discussion and analysis of the domestic taxation of international transactions. It is uniquely organized around the great divide within the United States international taxing system, namely domestic persons' "outbound" activities outside the United States and foreign persons' "inbound" activities within the United States. The eleventh edition has been substantially revised to integrate the far-reaching statutory and regulatory changes brought about by the landmark 2017 tax legislation, popularly known as the Tax Cuts and Jobs Act of 2017. Volume 1 addresses outbound transactions and activities, where United States individuals and businesses work and invest abroad. Among other topics covered, this volume discusses the domestic residency requirements, the sourcing rules, the section 911 exclusion for United States citizens working abroad, the foreign-derived intangible income (FDII) regime, the participation dividends-received deduction (DRD), the foreign tax credit provisions, the limitations imposed on non-recognition outbound property transfers, the transfer pricing requirements, and the controlled foreign corporation and passive foreign investment company anti-deferral provisions. The global intangible low-taxed income (GILTI) regime is discussed at length in the chapter on controlled foreign corporations. Volume 2 addresses inbound transactions and activities, where foreign individuals and businesses work and invest within the United States. Among other topics covered, this volume discusses the foreign residency requirements, the United States taxable presence of foreign persons, the effectively connected income requirements, the branch profits taxes, the Foreign Investment in Real Property Tax Act (FIRPTA), the tax treaty qualifications and limitations, the taxing provisions of international partnerships, the limitations imposed on non-recognition inbound property transfers, and the various anti-base erosion constraints, including the base erosion and anti-abuse tax (BEAT) and the earnings stripping provisions. The Model United States Income Tax Treaty, United States-Canada Tax Treaty, and the associated Treasury Department Technical Explanations are included in the appendices. This two-volume treatise is current through May 30, 2021, and is available only as a set.

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Are you ready to take your knowledge of international taxation to the next level? Look no further than the United States International Taxation (2 Volumes): Outbound and Inbound Activities. This comprehensive two-volume treatise is your ultimate guide to understanding and navigating the complex world of international transactions. With its detailed discussion and analysis of domestic taxation, this book is a must-have for tax professionals and business owners alike.

What sets this treatise apart is its unique organization around the two key aspects of the United States international taxing system: "outbound" activities of domestic persons outside the United States, and "inbound" activities of foreign persons within the United States. By delving into both perspectives, this book provides a comprehensive understanding of the challenges and opportunities presented by international transactions.

The eleventh edition has been extensively updated to reflect the significant changes brought about by the landmark 2017 tax legislation, making it current and relevant in today's ever-changing tax landscape. You can trust that the information and insights provided in this treatise are up-to-date and accurate.

Volume 1 focuses on outbound transactions and activities, equipping readers with the necessary knowledge to navigate working and investing abroad. From residency requirements to transfer pricing, foreign tax credits to controlled foreign corporations, this volume covers it all. No matter your level of expertise, you'll find valuable information and practical guidance to enhance your understanding of outbound activities.

Volume 2 dives into inbound transactions and activities, shedding light on the intricacies of foreign individuals and businesses working and investing within the United States. From residency requirements to branch profits taxes, tax treaty qualifications to anti-base erosion constraints, this volume provides comprehensive coverage of inbound activities. Expand your knowledge and make informed decisions with the insights provided in this volume.

As a bonus, the appendices include the Model United States Income Tax Treaty, United States-Canada Tax Treaty, and the associated Treasury Department Technical Explanations. These additional resources further enhance your understanding of international tax treaties, providing you with valuable reference materials.

Don't miss out on this invaluable resource for international taxation. Stay ahead of the curve and make informed decisions with the United States International Taxation (2 Volumes): Outbound and Inbound Activities. Order your set today and take your international tax knowledge to new heights.

Order now and empower yourself with the comprehensive knowledge of international taxation.

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