International Tax Research Guide: Casebooks & Study Aids

Series: Elements of International Law.
This book's abstract states it can "serve as a course book for a course on international tax law." Excerpt from this book's description: "Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these."
Contents: 1. Introduction - 2. Sources of the International Law of Taxation - 3. Relationship with Other Areas of International Law - 4. Conceptual Problems - Index.

Contents: General - Jurisdiction to Tax and Definitions - The Source of Income - The Allocation of Deductions - U.S. Income of Foreign Taxpayers - The Taxation of Non-business Income - The Taxation of Business Income -The Transfer Pricing Problem - The Transfer Pricing Problem: Foreign Income of U.S. Taxpayers - Deferral and Its Llimits - The Foreign Tax Credit - The U.S. and the International Tax Regime - Section 367 & Cross-border Transfer of Property - Foreign Currency - The Role of Treaties - The Future of the International Tax Regime.

Contents: Part I. Foundations of International Taxation - Residency Classification Rules - Source Rules - Part II. Introduction to the Treatment of Outbound Activities - Foreign Earned Income of United States Persons - Foreign Tax Credit: Overview - Foreign Tax Credit: The "Deemed Paid" Credit - Foreign Tax Credit: The [section] 904 Limitations - Part III. Inbound Taxation - Treatment of Foreign-owned United States Investment Income - Treatment of Foreign-owned United States Business Income - Taxation of Branch Profits and Investment in United States Real Property - Overview of Tax Treaties - Tax Treaties and Investment Income - Tax Treaties and Business Income - Part IV. Safeguards - Introduction to Controlled Foreign Corporations - Controlled Foreign Corporations: Subpart F Income - Passive Foreign Investment Companies.

Contents: I. Introduction -- II. How to research international taxation -- III. Primary sources -- IV. Secondary sources -- V. U.S. international taxation -- VI. Online research -- VII. Conclusion.

This primer includes the sections: Ch. 1. Introduction - Ch. 2. Jurisdiction to Tax - Ch. 3. Double Taxation Relief - Ch. 4. Transfer Pricing - Ch. 5. Anti-Avoidance Measures - Ch. 6. Tax Treaties - Glossary of International Tax Terms.
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The compendium includes the chapters: Ch.1 Introduction - Ch. 2 The United States Income Tax System: General Description - Ch. 3 Jurisdictional Principles - Ch. 4 Source Rules - Ch. 5 Income Taxation of Nonresident Aliens and Foreign Corporations - Ch. 6 Treatment of Foreign Business Operations and Investments by US Persons - Ch. 7 Formation, Reorganization, and Liquidation of Foreign Corporations: Section 367 - Ch. 8 Foreign Investment Activities by US Persons Utilizing Foreign Corporations - Ch. 9 Taxation of Foreign Source Income of US Persons: The Foreign Tax Credit - Ch. 10 Limitations on the Foreign Tax Credit - Ch. 11 Special Treatment of Foreign Income - Ch. 12 Transfer Pricing - Ch.13 Foreign Currency Issues - Ch. 14 Income Tax Treaties - Ch. 15 Wealth Transfer Taxation.

This primer includes the sections: I. How to Work With an Income Tax Treaty - II. How Modern Income Tax Treaties Are Designed and Structured - III. Interpreting an Income Tax Treaty - IV. Turning Treaties into Law and Terminating Treaty Relationships - V. Changes in Territory - VI. Multilateral Income Tax Treaties - VII. The MLI's Substantive Provisions - Appendix 1. Types of Tax Treaties - Appendix 2. The Historical Development Of Model Income Tax Treaties - Appendix 3. Diplomatic Status Of Types Of International Agreement - Appendix 4. Breakup of the Former USSR, Yugoslavia and Czechoslovakia.
Available in subscription database Bloomberg Law.

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.

Contents: Overview of Fundamental Concepts - Introduction - Basic U.S. Jurisdictional Tax Principles - Source Rules - U.S. Activities of Foreign Taxpayers - Taxing Rules for Non-U.S. Persons - The Role of Income Tax Treaties - Filing, Withholding, and Reporting Requirements - Foreign Activities of U.S. Taxpayers - Introduction to U.S. Business Activity in Foreign Countries - Introduction to the Foreign Tax Credit - Taxation of U.S. Persons' Foreign Income Earned in Corporate Form - Limitations on the Foreign Tax Credit and the Indirect Credit - Intercompany Ppricing - Foreign Currency - International Tax-free Transactions - Tax Arbitrage and an Evolving Global Tax Landscape - Tax and Trade and Foreign Policy.

Concise Hornbook Series.
Includes chapters: Standards to Judge the Tax System - International Taxation.

Includes chapters: Criteria in Evaluating a Tax System - International Tax.