Basics of International Taxation 2017

Front Matter
Faculty Bios
Table of Contents
Chapter 1. Overview of U.S. International Tax System
Chapter 2. US Persons Operating Outside the United States: Outbound Active Business Operations (April 2017)
Chapter 3. U.S. Persons Investing or Operating Outside of the United States (Outbound Investments)—Lending, Licensing, and Portfolio Investments
Chapter 4. U.S. Persons Investing or Operating Outside of the United States (Outbound Investments)—Lending, Licensing, and Portfolio Investments (PowerPoint slides)
Chapter 5. Tax Reporting and Dealing with Noncompliance
Chapter 6. The IRS Reached the Expert Level in Offshore Matters: Tax Professionals Must Be Aware of the Remediation Options for Undisclosed Offshore Assets (May 1, 2017)
Chapter 7. The IRS Reached the Expert Level in Offshore Matters: Tax Professionals Must Be Aware of the Remediation Options for Undisclosed Offshore Assets (PowerPoint slides)
Chapter 8. An Introduction to the Foreign Tax Credit (April 2017)
Chapter 9. Overview of U.S. Tax Treaties (April 28, 2017)
Chapter 10. An Introduction to the Foreign Tax Credit (PowerPoint slides)
Chapter 11. Foreign Currency Transactions and Foreign Currency Translation Gain and Loss Section 987 Foreign Branch Currency Regulations (May 2017)
Chapter 12. Sullivan & Cromwell Client Memo: 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 13. Cooley Alert: New US Debt-Equity Rules Target Earnings Stripping (October 20, 2016)
Chapter 14. Transfer Pricing and Section 482: An Overview of U.S. Transfer Pricing Rules
Chapter 15. Transfer Pricing (PowerPoint slides)
Chapter 16. Miller & Chevalier Memorandum: Cross-Border Services and Employment Tax Issues (April 29, 2016)
Chapter 17. Cross-Border Services and Employment Tax Issues (PowerPoint slides)
Chapter 18. PwC Tax Insights: Trump Administration Officials Announce Tax Reform Principles (April 26, 2017)
Chapter 19. PwC Tax Insights: The House Republican Blueprint: A Destination-Based Cash-Flow Tax (January 18, 2017)
Index