International Taxation: Corporate and Individual

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.