U.S. Taxation of International Transactions (American Casebook Series)

Part I covers tax treaties and U.S. taxation of personal-service income of nonresident aliens. Part II covers federal income taxation of U.S. operations of foreign entities and the U.S. taxation of the U.S. source non-trade or business income of nonresident aliens and foreign corporations; foreign-controlled U.S. corporations; sale or liquidation; and taxable and tax-free acquisitions. Part III covers federal income taxation of foreign operations of U.S. persons, foreign tax credit, sourcing rules and foreign currency roles, dividends, and partnerships. Part IV covers tax policy.