U.S. taxation in the international setting -- Nationality and residence for taxation -- The source of income -- International transfer pricing -- U.S. taxation of foreign persons: passive investment income -- The meaning of a U.S. "trade or business" -- "Effectively connected" income -- Gains from sales of U.S. real property -- The branch profits tax -- Outbound taxation in overview -- The foreign tax credit: background and overview -- The foreign tax credit: creditable foreign taxes -- The credit limitation of section 904 -- The indirect foreign tax credit -- Grand overview of dividends from foreign corporations -- Controlled foreign corporations: subpart F -- Controlled foreign corporations: section 1248 -- Passive Foreign Investment Companies (PFICs) -- International corporate reorganizations -- U.S. citizens abroad -- Income tax incentives for exports -- Income tax treaties in overview -- Residence in income tax treaties -- Business profits: permanent establishments -- Compensation for personal services -- Interest, dividends, royalties, rents, and other gains -- The rise and fall of treaty tax shelters: sandwiches, conduits, and the treasury's response.
This resource is supported by the Institute of Museum and Library Services under the provisions of the Library Services and Technology Act as administered by State Library of Iowa.