Detailed analysis. Essential elements of U.S. international taxation -- Inbound U.S. taxation -- Outbound U.S. taxation -- International corporate reorganizations -- Income tax treaties -- The question of characterization -- International tax shelters -- Working papers.
Summary:
" ... provides an introduction to and overview of the application of the U.S. income tax system in the international environment. U.S. international taxation extends to two fundamental types of transactions: (1) investments or undertakings of U.S. persons outside the United States (outbound transactions); and (2) investments or undertakings of foreign persons in the United States (inbound transactions)."
