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United States Taxation of International Transactions

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ISBN-10: 031404745X

ISBN-13: 9780314047458

Edition: 1995

Authors: Samuel C. Thompson

List price: $69.00
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Book details

List price: $69.00
Copyright year: 1995
Publisher: West Publishing Company, College & School Division
Binding: Hardcover
Pages: 610
Size: 8.00" wide x 10.50" long x 1.25" tall
Weight: 3.146
Language: English

Preface
Acknowledgements
Table of Cases
Table of Internal Revenue Code Sections
Table of Revenue Rulings and Procedures
Table of Treasury Regulations
Scopep. 1
Introduction to Tax Treatiesp. 30
U.S. Taxation of the Personal Service Income of Nonresident Aliensp. 65
U.S. Taxation of the U.S. Source Non-Trade or Business Income of Nonresident Aliens and Foreign Corporationsp. 72
Organizing and Operating a United States Business: Foreign Controlled U.S. Corporations, Branches, and Partnershipsp. 113
Sale or Liquidation of Foreign Controlled U.S. Corporationp. 181
Taxable and Tax-Free Acquisitions of Domestic Corporations by Foreign Corporationsp. 190
Organization and Operation of Foreign Branches by U.S. Persons: Impact of Foreign Tax Credit, Sourcing Rules, and Foreign Currency Rolesp. 223
Organization of Foreign Corporations and Foreign Partnershipsp. 348
Treatment of Actual and Imputed Dividends to U.S. Corporate Shareholders of Foreign Corporations: The Indirect Foreign Tax Credit, Look Through Rules, Resourcing Rules, Dividends Received Deduction, and Foreign Currency Rulesp. 373
Section 482: Transactions Between Commonly Controlled Corporationsp. 397
Controlled Foreign Corporationsp. 443
Foreign Personal Holding Companiesp. 521
Passive Foreign Investment Companiesp. 530
The Foreign Sales Corporationp. 548
Possessions Corporationsp. 565
Taxable Sale or Liquidation of a Foreign Corporation and Impact of Section 1248p. 580
Tax-Free Acquisitions, Liquidations and Spinoffs of Foreign Corporations and Impact of Section 338 on Taxable Acquisitions of the Stock of Foreign Corporationsp. 588
Indexp. 607
Table of Contents provided by Blackwell. All Rights Reserved.