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Basics of International Taxation 2015
John L. Harrington, Linda E. Carlisle
International Law, Tax
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Table of Contents
Table of Contents
Chapter 1. Overview of U.S. International Tax System
Chapter 2. Overview of U.S. Tax Treaties (May 19, 2015)
Chapter 3. New Guidance for Cross-Border Stock Transfers (Tax Notes, April 16, 2012)
Chapter 4. Revisiting Certain Fundamentals in Light of The New Wave of Outbound Reorganization Guidance (42 TMIJ 21, January 11, 2013)
Chapter 5. Outbound Investments—Treatment of Lending, Licensing and Portfolio Investments under Subpart F and PFIC Rules (April 24, 2015)
Chapter 6. An Introduction to the Foreign Tax Credit
Chapter 7. Reporting and Voluntary Compliance Initiatives (FBAR and Other U.S. International Tax Reporting Issues for U.S. and Foreign Taxpayers)
Chapter 8. Compliance Options Available Prior to the IRS Catching Your Client Who Has Undisclosed Offshore Assets and Income (April 24, 2015)
Chapter 9. Inversions, Outbound Transfers of Business Assets and Expatriation Consequences
Chapter 10. IRS Releases Chief Counsel Advice Memorandum 201501013, Treating a Foreign Fund with No Employees as Engaged in a Trade or Business in the United States Through the Lending and Underwriting Activities of the Fund’s Manager, and Clarifying Trading Safe Harbors (January 26, 2015)
Chapter 11. Inbound Taxation
Chapter 12. Transfer Pricing and Section 482: An Overview of U.S. Transfer Pricing Rules
Chapter 13. Transfer Pricing (PowerPoint slides)
Chapter 14. Cross-Border Services and Employment Tax Issues
Chapter 15. Cross-Border Services and Employment Tax Issues (PowerPoint slides)
Chapter 16. Update on OECD BEPS Project
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