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U.S. International Taxation quickly and efficiently delivers answers to any and all key questions concerning international taxation. Authors Joel D. Kuntz, an international tax practitioner, and Robert J. Peroni, an international tax professor, cover the full range of international tax topics, everything from taxation of foreign corporations held by Americans to taxation of U.S. corporations held by foreigners.
The one-stop reference and practical analysis of the laws, regulations, treaties, and decisions governing U.S. taxation of U.S. persons with foreign income and foreign persons with U.S. income. The perfect primer for international tax research, it is also ideal as a check and confirmation resource on specific issues.
The treatise is organized on a transactional basis rather than by discrete points of law and covers the full scope of international taxation topics with in-depth guidance on:
¦ Taxation of foreign corporations owned by U.S. persons
¦ Taxation of U.S. corporations owned by foreign persons
¦ Special treatment of controlled foreign corporations and passive foreign investment companies
¦ Foreign tax credits
¦ Withholding for foreign persons with U.S. income
¦ Benefits of income tax treaties
¦ Taxation relating to possessions
¦ Hidden IRS Notice changes to regulations |