International Applications Of U.s. Income Tax Law: Inbound And Outbound Transactions (wiley Finance)

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A clear, concise explanation of United States tax law’s international aspectsIn tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes:Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estateWhat a controlled foreign corporation is and what consequences result from this statusAcceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principlesInternational Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present.Order your copy today!

E-Book Content

International Applications of U.S. Income Tax Law International Applications of U.S. Income Tax Law Inbound and Outbound Transactions ERNEST R. LARKINS John Wiley & Sons, Inc. This book is printed on acid-free paper. Copyright © 2004 by John Wiley & Sons, Inc. All rights reserved. Published by John Wiley & Sons, Inc., Hoboken, New Jersey Published simultaneously in Canada No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, 978-750-8400, fax 978-750-4470, or on the web at www.copyright.com. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons, Inc., 111 River Street, Hoboken, NJ 07030, 201-748-6011, fax 201-748-6008, e-mail: [email protected] Limit of Liability/Disclaimer of Warranty: While the publisher and author have used their best efforts in preparing this book, they make no representations or warranties with respect to the accuracy or completeness of the contents of this book and specifically disclaim any implied warranties of merchantability or fitness for a particular purpose. No warranty may be created or extended by sales representatives or written sales materials. The advice and strategies contained herein may not be suitable for your situation. You should consult with a professional where appropriate. Neither the publisher nor author shall be liable for any loss of profit or any other commercial damages, including but not limited to special, incidental, consequential, or other damages. For general information on our other products and services, or technical support, please contact our Customer Care Department within the United States at 800-762-2974, outside the United States at 317-572-3993 or fax 317-572-4002. Wiley also publishes its books in a variety of electronic formats. Some content that appears in print may not be available in electronic books. For more information about Wiley products, visit our web site at www.wiley.com. Library of Congress Cataloging-in-Publication Data: Larkins, Ernest R. (Ernest Radford) International applications of U.S. income tax law : inbound and outbound transactions / by Ernest R. Larkins. p. cm. Includes index. ISBN 0-471-46449-X (cloth : acid-free paper) 1. Income tax—United States—Foreign income. 2. Investments, Foreign—Taxation— Law and legislation—United States. 3. Aliens—Taxation—Law and legislation—United States. 4. Foreign
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