This two-volume treatise covers the United States taxation of foreign persons and foreign income. Volume 1 analyzes "outbound" transactions, with detailed chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. The Fourth Edition features extensive discussion of the extraterritorial income exclusion and the newly finalized regulations relating to outbound transfers of stock and securities. Volume 2 addresses "inbound" transactions, with comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons and dispositions of interests in United States real property. The Fourth Edition contains comprehensive chapters on tax treaties and an overview of the new regulations relating to inbound liquidation and reorganization transactions. Each volume also contains new chapters on international partnership transactions, and reflects other new statutes, regulations, rulings, and cases.

International Taxation: Corporate and Individual

Donaldson, Samuel

Postlewaite, Philip

Carolina Academic Press

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.

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

Weiss, Mitchell

Foreign & International Law

United States International Taxation embodies dual goals: to provide graduate tax students with a solid foundation in the applicable rules of a given area and to enhance their skills in reading and applying complex statutes and regulations. This fourth edition has been revised to integrate the far-reaching changes brought to the subject by the landmark legislation enacted in the Tax Cut and Jobs Act ( TCJA ) in December 2017. The fourth edition focuses on key concepts (i.e., outbound, inbound, and safeguard issues) that can and should reasonably be covered in a one-semester introductory course on international taxation employing the use of the problem method of instruction. An updated teacher's manual accompanies the revised student problems that integrate and address the dramatic changes of the TCJA. Finally, given their importance in the international arena, the text addresses the role of tax treaties. The problems therein involve Canadian taxpayers engaged in inbound transactions. The appendix reproduces the text of the United States Canada Treaty as well as its Technical Explanations in order to afford the students a real-world experience.

United States International Taxation (Graduate Tax Series)

Tokic, Genevieve

Sheffield, Jeffrey

United States International Taxation embodies two complementary goals: to provide tax students with a solid foundation in the applicable international tax rules and to enhance their skills in analyzing and applying complex statutes, regulations, and tax treaties. This fifth edition incorporates the tax law changes that have occurred since the publication of the fourth edition and also includes two new chapters that, from an inbound and outbound perspective, delve into the tax consequences attending cross-border partnership activities.\nConsisting of 17 chapters, this casebook provides a streamlined discussion of the most important concepts of the international tax law in the United States, including: residency and sourcing of income; the taxation of United States persons (citizens, residents, and domestic corporations) on their activities abroad (outbound transactions); the taxation by statute and treaties of foreign persons (nonresident alien individuals and foreign corporations) on their activities within the United States (inbound transactions); and the rules in place to curtail potentially abusive tax deferral in the international context through the use of foreign corporations by United States persons (safeguard provisions). 
As with prior editions, the fifth edition employs a problem-based approach. The model answers to these problems are set forth in an updated teacher's manual. Finally, given their importance in the international arena, the casebook addresses the role of tax treaties and includes in the appendix a reprint of the United States-Canada Tax Treaty and the Treasury Department's technical explanations of the various protocols thereof.

Tax Law

This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.This two-volume treatise is available only as a set.

Hoffer, Stephanie

This two-volume treatise covers domestic taxation of foreign individuals and businesses that have income connected to the United States, as well as domestic taxation of foreign income earned by United States individuals and businesses. Volume 1 analyzes ''outbound'' transactions, where United States individuals and businesses work and invest abroad, and it includes chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. This volume also addresses limitations and safeguard regimes for outbound transactions. Volume 2 addresses ''inbound'' transactions, where foreign individuals work and invest in the United States, and it contains comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons, and dispositions of interests in United States real property. The volumes also provide a new and detailed discussion of the effect of international tax treaties on both inbound and outbound transactions.

International Taxation (2 volumes): Corporate and Individual

One of our popular LexisNexis Graduate Tax Series titles, United States International Taxation embodies the dual goals established for the Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. This third edition has been revised to provide a more streamlined approach, limited to 15 units, to the fundamental concepts of international taxation, including:residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities abroad,the taxation of foreign persons (nonresident alien individuals and foreign corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax deferral in the international context.The Third Edition focuses on key concepts (i.e., outbound, inbound, and safeguard issues) that can and should reasonably be covered in a one-semester introductory course on international taxation employing the use of the problem method of instruction. Additions to the reference materials are also included in the third edition, and an updated teacher’s manual accompanies the revised student problems. Finally, the approach addresses the powerful role of tax treaties in the international context and in the appendixes reproduce the text of the United States Model Income Tax Treaty and the United States-Canada Treaty as well as their Technical Explanations.

Green Baumeister, Julie

See the best price to sell, buy, or rent books by Postlewaite, Philip. BookScouter helps to compare book prices from 25+ online bookstores and 30+ buyback vendors with a single search.

Books by Postlewaite, Philip

See the best price to sell, buy, or rent books by Postlewaite, Philip. BookScouter helps to compare book prices from 25+ online bookstores and 30+ buyback vendors with a single search.

International Taxation: Corporate and Individual

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

United States International Taxation (Graduate Tax Series)

United States International Taxation (Graduate Tax Series)

International Taxation: Corporate and Individual

International Taxation (2 volumes): Corporate and Individual

United States International Taxation (Graduate Tax Series)