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United States international taxation : outbound and inbound activities
Uniform Title
International taxation.
Title
United States international taxation : outbound and inbound activities / Philip F. Postlewaite, Mitchell B. Weiss.
ISBN
9781531011161
1531011160
Edition
Eleventh Edition.
Publication
Durham, North Carolina : Carolina Academic Press, [2022]
Physical Description
2 volumes : illustrations ; 27 cm.
Other editions
Postlewaite, Philip F., 1945- International taxation. Tenth edition. Durham, North Carolina : Carolina Academic Press, [2016]
Format
Books
Language
English
Added to Catalog
January 24, 2023
Bibliography
Includes bibliographical references and index.
Contents
Volume 1 : Outbound
Preface
Introduction
Chapter 1 Residency
Chapter 2 Source rules
Chapter 3 Section 911 exclusion : taxation of United States individuals working abroad
Chapter 4 Export Activities
Chapter 5 Tax treaties
Chapter 6 Participation dividends-received deduction
Chapter 7 Transition tax
Chapter 8 Foreign tax credit
Chapter 9 Controlled foreign corporations
Chapter 10 Passive foreign investment companies and other anti-deferral measures
Chapter 11 Outbound transfers of property
Chapter 12 Section 482 : international transactions among related parties - outbound
Chapter 13 International partnerships and partners - outbound considerations
Appendix A United States model income tax convention of November 15, 2006
Appendix B United States model technical explanation accompanying the United States model income tax convention of November 15, 2006
Statutes
Treasury regulations
Revenue rulings
Revenue procedures
Private letter rulings
Technical advice memoranda
General counsel memoranda
Notices
Table of cases
Index
Volume 2 : Inbound
Preface
Introduction
Chapter 14 Non-residency
Chapter 15 Tax treaties - an overview
Chapter 16 Tax treatise and business income
Chapter 17 Tax treaties and passive income
Chapter 18 Source rules
Chapter 19 Trade of business status
Chapter 20 Taxation of foreign persons
Chapter 21 Dispositions of investments in United States real property
Chapter 22 Section 367 : inbound transfers of property
Chapter 23 Section 482 : international transactions among related parties - inbound
Chapter 24 International partnerships and partners - inbound considerations
Appendix C Convention between the United States of America and Canada with respect to taxes on income and on capital
Appendix D Treasury department technical explanation of the convention between the United States of America and Canada with respect to taxes on income and on capital signed at Washington, D. C. on September 6, 1980, as amended by the protocol signed at Ottawa on June 14, 1983 and the protocol signed at Washington on March 28, 1984
Appendix E Department of the treasury technical explanation of the protocol done at Chelsea on September 21, 2007 amending the convention between the United States of America and Canada with respect to taxes on income and on capital done at Washington on September 26, 1980, as amended by the protocols done on June 14, 1983, March 28, 1994, March 17, 1995, and July 29, 1997
Statutes
Treasury regulations
Revenue rulings
Revenue procedures
Private letter rulings
Technical advice memoranda
General counsel memoranda
Notices
Table of cases
Index.
Subjects
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