International Aspects of the US Taxation System

Felix I. Lessambo is Adjunct Associate Professor at the Peter J. Tobin College of Business at St. John's University, USA. He practiced in international tax and alternative investment management groups where he structured and advised on hedge funds and private equity cross-border transactions. He is the author of several books in finance, including The International Banking System, The International Corporate Governance System, and International Financial Institutions and Their Challenges.

1 Overview.- 2 The Underlying Principles of the US Tax System.-   3 US Inbound taxation.- 4 The Split of Tax Jurisdiction: The Source Rules.- 5 The US Taxing Regime of Foreign Taxpayers.- 6 The Branch Profits Tax.- 7 Foreign Investment in Real Property Transaction Act.- 8 The Taxation of Foreign Sovereign in the United States.- 9 The International Tax Treaty Rules.- 10 Foreign Account Tax Compliance Act.- 11 Taxation Regime of Expatriates and Corporate Inversion.- 12 The Investments of US Individuals or Corporations Abroad.- 13 The US Foreign Tax Credit Regime.- 14 The Subpart F Regime.- 15 Taxation of Derivatives.- 16 The Taxation of Foreign Currency.- 17 Domestic International Sales Corporation.- 18 International Outbound Transactions.- 19 Cross-Border Tax Arbitrage.- 20 Base Erosion and Profit Shifting.