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International Applications of U.S. Income Tax Law: Inbound and Outbound Transactions


Praise for International Applications of U.S. Income Tax Law

"Dr. Larkins has created a concise and easy-to-read summary of the essentials of international taxation. His text offers valuable insights and observations into many of the issues and topics that surface frequently in practice. The book's practical examples and citations make it a helpful summary for the beginner as well as the more experienced practitioner."
––Steve McLeighton
Partner, International Corporate Tax Services

"International Applications of U.S. Income Tax Law is an excellent addition to the international taxation literature. The book deals with an extremely important and complex area, and does an excellent job of making it understandable. Larkins provides an overview of the issues, a discussion of inbound and outbound transactions, and a discussion of major areas of concern in international taxation. The book also provides numerous tax planning and tax policy perspectives. International Applications of U.S. Income Tax Law is unique from other books in this area because it contains numerous examples, marginal tax rate analysis when applicable, and links to empirical studies involving issues in international taxation. It is an excellent text but also an excellent reference book."
––Thomas M. Porcano
Arthur Andersen Alumni Professor of Accountancy, Miami University
Editor of Advances in Taxation

"Larkins's text presents all the subject areas necessary to understand the U.S. tax rules affecting foreign persons investing in the United States and U.S. persons investing overseas. The text will benefit experienced international tax practitioners as well as tax generalists seeking to learn about the international aspects of the U.S. income tax law. The illustrations are particularly useful in enabling readers to advise clients how to achieve their tax objectives and how to avoid unintended pitfalls."
––W. Theodore Kresge Jr.
Retired International Tax Partner

"Professor Larkins provides a lucid and informative guide to the international provisions of U.S. tax law. The text is an effective learning tool in both substance and style and is equally useful for students being introduced to international tax for the first time or professionals seeking a concise reference guide."
––Gary McGill, PhD, CPA
PricewaterhouseCoopers Term Professor
University of Florida

Ernest R. Larkins is the E. Harold Stokes/KPMG Professor of Accounting at Georgia State University, where he teaches graduate courses in federal tax research and international taxation. He has published approximately 100 articles in various academic, law, and professional journals, as well as several chapters in books and monographs. He has received research fellowships from the Australian Taxation Studies Program (ATAX), University of New South Wales, and, for work conducted in Russia, the Society of International Business Fellows. He is an active member of the American Accounting Association and the American Taxation Association.

PART ONE: Generic Topics.

CHAPTER 1: Policy and Overview.

International Tax Policy.

Entity Selection.

Generic Topics.

Inbound Transactions.

Outbound Transactions.

Related Person Transactions.

CHAPTER 2: Jurisdiction to Tax.

Tale of Two Systems.

U.S. Jurisdiction.

Double Taxation.

CHAPTER 3: Income Tax Treaties.

Treaty Creation and Authority.

Treaty Scope.

Personal Service Income.

Business Profit.

Investment Income.

Gain from Dispositions.

Special Clauses.

CHAPTER 4: Source of Income.

Fundamental Importance.

General Source Rules.

Interest Income.

Dividend Income.

Personal Service Income.

Rent and Royalty Income.

Gain from Selling Property.

Other Source Rules.

CHAPTER 5: Allocation and Apportionment.

Allocation to Classes.

Apportionment to Groupings.

Interest Deductions.

Research and Experimental Deductions.

Other Deductions.

PART TWO: Inbound Transactions.

CHAPTER 6: Foreign Persons.

Residency Tests.

Counting Days.

Dual Status Aliens.

Important Elections.

CHAPTER 7: Nonbusiness Income.

Fixed or Determinable, Annual or Periodical Income.

Marginal Tax Rates.

Nonbusiness Exemptions.

Interest Stripping.

CHAPTER 8: Business Income.

U.S. Trade or Business.

Effectively Connected Income.

Business Exemptions.

Income Tax Calculations.

CHAPTER 9: Real Property Gains.

U.S. Real Property Interests.

U.S. Real Property Holding Corporations.

Withholding Procedures.

Structures for Holding U.S. Real Estate.

CHAPTER 10: Branch Taxes.

Branch Profits Tax.

Marginal Tax Rates.

Branch Interest Tax.

PART THREE: Outbound Transactions.

CHAPTER 11: Foreign Tax Credit.

Creditable Taxes.

Deemed Paid Taxes.

Limitation Formula.

Tax-Sparing Credit.

CHAPTER 12: Controlled Foreign Corporations.

CFCs and U.S. Shareholders.

Subpart F Income.

Earnings Invested in U.S. Property.

Constructive Dividends.

CHAPTER 13: Other Antideferral Provisions.

Passive Foreign Investment Companies.

Qualified Electing Funds.

Foreign Personal Holding Companies.

CHAPTER 14: Export Incentives.

Extraterritorial Income Exclusion.

Domestic International Sales Corporations.

CHAPTER 15: U.S. Individuals Abroad.

Foreign Earned Income Exclusion.

Income Sourced in U.S. Possessions.

Social Security Concerns.

PART FOUR: Related Person Transactions.

CHAPTER 16: Transfer Prices.

General Principles.

Loan of Funds.

Performance of Services.

Rental of Tangible Property.

Sale or License of Intangible Property.

Sale of Tangible Property.

Valuation Misstatements.

Advance Pricing Agreements.

CHAPTER 17: Asset Transfers.

Outbound Asset Transfers.

Inbound Asset Transfers.

External Asset Transfers.


Table of Statutes.

Table of Regulations.

Table of Cases.

Table of Rulings.