International Taxation by Bret WellsCall Number: KF6419 .I83 2022 (Reserve)
Publication Date: 5th ed. 2022
Contents: U.S. taxation in the international setting -- Nationality and residence for taxation -- The source of income -- International transfer pricing -- U.S. taxation of foreign persons : passive investment income -- U.S. taxation of foreign persons : taxation of a trade or business -- Income tax treaties -- Inbound base protection measures that backstop inbound taxation -- Outbound U.S. taxation in overview -- Direct foreign investment : the foreign tax credit regime -- Controlled foreign corporations -- Passive Foreign Investment Companies (PFICs) -- Dispositions, liquidations, and reorganizations of controlled foreign corporations and incorporations of foreign branches -- Miscellaneous foreign incentives regimes.