International Aspects of the US Taxation System

Authors: Felix I. Lessambo



Provides real illustrations of complex US tax policies

Details inbound and outbound taxes separately

Ideal for practitioners specializing in a particular area

This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.

Table of contents (20 chapters)

Front Matter

Overview

The Underlying Principles of the US Tax System

Inbound Taxation

The Split of Tax Jurisdiction: The Source Rules

The US Taxing Regime of Foreign Taxpayers

The Branch Profits Tax

Foreign Investment in the Real Property Transaction Act

The Taxation of Foreign Sovereign in the United States

The International Tax Treaty

Foreign Account Tax Compliance Act

Taxation Regime of Expatriates and Corporate Inversion

The Investments of US Individuals or Corporations Abroad

The US Foreign Tax Credit Regime

The Subpart F Regime

Taxation of Derivatives

The Taxation of Foreign Currency

Domestic International Sales Corporation

International Outbound Transactions

Cross-Border Tax Arbitrage

Base Erosion and Profit Shifting

Back Matter

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