U.S. International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions

This book addresses the federal income tax treatment of (1) foreign individuals and corporations in the U.S. (i.e., inbound transactions), and (2) U.S. individuals and corporations abroad (i.e., outbound transactions). After considering basic principles and treaties in Part I, Part II deals with inbound transactions; Part III addresses outbound transactions; and Part IV focuses on cross-border mergers and acquisitions. In many chapters the book compares the U.S. approach with the approach taken under the income tax law of South Africa, which has an income tax treaty with the U.S.