Introduction To United States International Taxation 7th Edition By James Repetti, Diane Ring, Stephen Shay
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- 222
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- 4.91 MB
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- Education
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The Introduction to United States International Taxation (7th Edition) by James R. Repetti, Diane M. Ring, and Stephen E. Shay provides a comprehensive structure of the U.S. international tax system for individuals, corporations, and other entities. [1, 2]
Spanning eleven chapters, the core topics covered in this edition include: [1]
- U.S. Income Tax System Overview: Basic foundational concepts concerning individual and corporate income taxes, accounting aspects, and the tax treatment of partnerships, trusts, and estates.
- Jurisdictional and Source Rules: The structural rules and basic jurisdictional principles the U.S. uses to apply income tax to cross-border business activities and international investments.
- Inbound Taxation (Taxing Foreign Persons): Rules governing how the U.S. taxes non-resident aliens, foreign corporations, partnerships, and trusts on investment and business income originating from U.S. sources.
- Outbound Taxation & Double Tax Alleviation: The mechanics and relief systems (such as the Foreign Tax Credit) designed to prevent or mitigate international double taxation on foreign-source income earned by U.S. citizens or residents.
- Controlled Foreign Corporations (CFCs) & Anti-Deferral: The tax treatment of foreign corporations controlled by U.S. shareholders, heavily emphasizing Post-TCJA regimes including GILTI (Global Intangible Low-Taxed Income) minimum tax regulations and exempt dividend rules.
- Foreign-Derived Intangible Income (FDII): Special tax rules and incentives covering U.S. corporations exporting goods, services, and intangible assets abroad.
- Transfer Pricing: General inter-company pricing and specialized transfer pricing regulations governing transactions between related international entities.
- Foreign Currency Transactions: Rules for treating financial transactions, gains, and losses denominated in currencies other than the U.S. dollar.
- Income Tax Treaties: Analysis of bilateral situations where specific U.S. income tax treaty provisions overrule or modify domestic statutory tax rules.
- Wealth Transfer Taxes: An overview of the U.S. estate and gift tax system as applied internationally, including modifications introduced by wealth transfer tax treaties. [1, 2, 3]
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