As more and more companies engage in global activity, practitioners must maintain a working knowledge of International tax law. This course covers all areas of international transactions including: currency issues, anti-avoidance provisions, transfer pricing, tax jurisdiction rules, foreign tax credits, source of income rules, and foreign sales corporations.

– Foreign Currency Translation and TransactionsThe book is organized into four parts: Basic Principles of U.S. Taxation of International Income, Taxation of Foreign Activities of U.S. Taxpayers, Taxation ofU.S. Activities of Foreign Taxpayers, and Taxation Issues Impacting Both U.S. and Foreign Taxpayers which discuss the following topics in detail:

PART I:  BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME

– Overview of U.S. Taxation of International Transactions

– Tax Jurisdiction

– Source of Income Rules

PART II:  TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS

– Foreign Tax Credit

– Deemed Paid Foreign Tax Credit

– Anti-Deferral Provisions

– Foreign Currency Translation and Transactions 

– Export Benefits

– Planning for Foreign Operations

– State Taxation of Foreign Operations

PART III:  TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS

– Foreign Persons Investing in the United States

– Foreign Persons Doing Business in the United States

– Planning for Foreign-Owned U.S. Operations

PART IV:  TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS

– Transfer Pricing

– Income Tax Treaties

– Cross-Border Transfers and Reorganizations

– International Tax Practice and Procedure

Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.