International Taxation: Cases, Materials, and Problems

As markets continue to globalize, international tax considerations multiply proportionately, if not geometrically. It is increasingly important that attorneys possess a working knowledge of the complex international tax provisions. The purpose of this work is to present the fundamental concepts of international taxation and their underlying policies. It stresses a problem-solving approach through the use of numerous, short problems interspersed among the relevant materials, which parallels a "real world" experience and thus helps to develop legal and analytic skills.

International Taxation is organized around three fundamental regimes of international taxation by the United States: (1) the basic rules of the United States with regard to taxing its domestic persons (i.e., citizens, residents, and domestic corporations) on their foreign activities; (2) the basic rules of the United States with regard to taxing nondomestic persons (i.e., nonresidents and foreign corporations) on their domestic activities; and (3) the safeguard rules employed by the United States in curbing the use by its domestic persons of foreign persons to conduct foreign activities.