International Applications of U.S. Income Tax Law: Inbound and Outbound Transactions

A clear, concise explanation of United States tax law’s international aspects. In 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 estate
・What a controlled foreign corporation is and what consequences result from this status
・Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles