International Applications of U.S. Income Tax Law

Ernest R. Larkins is the E. Harold Stokes/KPMG Professor of Accounting at Georgia State University, where he teaches graduate courses in federal tax research and international taxation. He has published approximately 100 articles in various academic, law, and professional journals, as well as several chapters in books and monographs. He has received research fellowships from the Australian Taxation Studies Program (ATAX), University of New South Wales, and, for work conducted in Russia, the Society of International Business Fellows. He is an active member of the American Accounting Association and the American Taxation Association.

Preface. PART ONE: Generic Topics.

CHAPTER 1: Policy and Overview.

International Tax Policy.

Entity Selection.

Generic Topics.

Inbound Transactions.

Outbound Transactions.

Related Person Transactions.

CHAPTER 2: Jurisdiction to Tax.

Tale of Two Systems.

U.S. Jurisdiction.

Double Taxation.

CHAPTER 3: Income Tax Treaties.

Treaty Creation and Authority.

Treaty Scope.

Personal Service Income.

Business Profit.

Investment Income.

Gain from Dispositions.

Special Clauses.

CHAPTER 4: Source of Income.

Fundamental Importance.

General Source Rules.

Interest Income.

Dividend Income.

Personal Service Income.

Rent and Royalty Income.

Gain from Selling Property.

Other Source Rules.

CHAPTER 5: Allocation and Apportionment.

Allocation to Classes.

Apportionment to Groupings.

Interest Deductions.

Research and Experimental Deductions.

Other Deductions.

PART TWO: Inbound Transactions.

CHAPTER 6: Foreign Persons.

Residency Tests.

Counting Days.

Dual Status Aliens.

Important Elections.

CHAPTER 7: Nonbusiness Income.

Fixed or Determinable, Annual or Periodical Income.

Marginal Tax Rates.

Nonbusiness Exemptions.

Interest Stripping.

CHAPTER 8: Business Income.

U.S. Trade or Business.

Effectively Connected Income.

Business Exemptions.

Income Tax Calculations.

CHAPTER 9: Real Property Gains.

U.S. Real Property Interests.

U.S. Real Property Holding Corporations.

Withholding Procedures.

Structures for Holding U.S. Real Estate.

CHAPTER 10: Branch Taxes.

Branch Profits Tax.

Marginal Tax Rates.

Branch Interest Tax.

PART THREE: Outbound Transactions.

CHAPTER 11: Foreign Tax Credit.

Creditable Taxes.

Deemed Paid Taxes.

Limitation Formula.

Tax-Sparing Credit.

CHAPTER 12: Controlled Foreign Corporations.

CFCs and U.S. Shareholders.

Subpart F Income.

Earnings Invested in U.S. Property.

Constructive Dividends.

CHAPTER 13: Other Antideferral Provisions.

Passive Foreign Investment Companies.

Qualified Electing Funds.

Foreign Personal Holding Companies.

CHAPTER 14: Export Incentives.

Extraterritorial Income Exclusion.

Domestic International Sales Corporations.

CHAPTER 15: U.S. Individuals Abroad.

Foreign Earned Income Exclusion.

Income Sourced in U.S. Possessions.

Social Security Concerns.

PART FOUR: Related Person Transactions.

CHAPTER 16: Transfer Prices.

General Principles.

Loan of Funds.

Performance of Services.

Rental of Tangible Property.

Sale or License of Intangible Property.

Sale of Tangible Property.

Valuation Misstatements.

Advance Pricing Agreements.

CHAPTER 17: Asset Transfers.

Outbound Asset Transfers.

Inbound Asset Transfers.

External Asset Transfers.

Glossary.

Table of Statutes.

Table of Regulations.

Table of Cases.

Table of Rulings.

Index.