内容

目次

Part I Foundations of International Taxation 1. Residency Classification Rules 2. Source Rules Part II Introduction to the Treatment of Outbound Activities 3. Foreign Earned income of United States Persons 4. Foreign Tax Credit: Overview 5. Foreign Tax Credit: the “Deemed Paid” Credit 6. Foreign Tax Credit: the §904 Limitations Part III Inbound Taxation 7. Treatment of Foreign-owned United States Investment Income 8. Treatment of Foreign-owned United States Business Income 9. Taxation of Branch Profits and Investment in United States Real Property 10. Overview of Tax Treaties 11. Tax Treaties and Investment Income 12. Tax Treaties and Business Income Part IV Safeguards 13. Introduction to Controlled Foreign Corporations 14. Controlled Foreign Corporations – Subpart F Income 15. Passive Foreign Investment Companies Appendix Table of Cases Table of Statutes Table of Secondary Authorities Index