CONTENTS
PART Ⅰ : BASIC PRINCIPLES
Chapter 1 : Tax Jurisdiction
Jurisdictional Issues = 101
Overview of U. S. Jurisdictional System = 102
Definition of Resident Alien = 103
Exclusion for Foreign Earned Income = 104
A Policy Note Regarding the Current U. S. System = 105
Appendix = 106
Chapter 2 : Source-of-Income Rules
Importance of Source Rules = 201
Source Rules for Gross Income = 202
Source Rules for Deductions = 203
PART Ⅱ : U.S. TAXATION OF FOREIGN INCOME
Chapter 3 : Foreign Tax Credit
Introduction = 301
Creditable Foreign Income Taxes = 302
Excess Versus Short Credit Positions = 303
Strategies for Eliminating Excess Credits = 304
Restrictions on Cross-Crediting = 305
Other Complexities of the Limitation = 306
Excess Credit Carryovers = 307
Computing the Alternative Minimum Tax Foreign Tax Credit = 308
Filing Requirements = 309
Appendix = 310
Chapter 4 : Deemed Paid Foreign Tax Credit
Taxation of Dividend Repatriations-Overview = 401
Who Can Claim a Deemed Paid Credit = 402
Computing the Deemed Paid Credit = 403
Filing Requirements = 404
Planning for Dividend Repatriations = 405
Chapter 5 : Transfer Pricing
What Is Transfer Pricing? = 501
Transfer Pricing Methods = 502
Information Reporting Requirements = 503
Transactional and Net Adjustment Penalties = 504
Developing a Transfer Pricing Strategy = 505
Chapter 6 : Anti-avoidance Provisions Governing Foreign Corporations
Subpart F = 601
Foreign Personal Holding Companies = 602
Foreign Investment and Passive Foreign Investment Companies = 603
Gain from the Sale or Exchange of a CFC's Stock = 604
Outbound Transfers to Foreign Corporations = 605
Special Rules for Noncorporate Foreign Entities = 606
Inbound Transfers from a Foreign Corporation = 607
Appendix = 608
Chapter 7 : Foreign Sales Corporations
Introduction = 701
Tax Benefits of an FSC = 702
Administrative Requirements = 703
Maximizing the FSC Benefit = 704
Interest-Charge DISCs = 705
Appendix = 706
Chapter 8 : Foreign Currency Translation and Transactions
Introduction = 801
Foreign Currency Translation = 802
Foreign Currency Transactions = 803
Chapter 9 : Tax Treaties
Introduction = 901
Common Treaty Provisions = 902
Disclosure of Treaty-Based Return Positions = 903
United States Model Income Tax Convention of September 20, 1996 = 904
Appendix = 905
Chapter 10 : Planning for Foreign Operations
Introduction = 1001
Evolution of a U. S. Exporter = 1002
Determinants of Host Country Taxation = 1003
Structuring the Foreign Operation = 1004
Basics of International Tax Planning = 1005
Comprehensive Example = 1006
Financial Reporting Implications of International Tax Planning = 1007
Survey of Foreign Entity Classification = 1008
Appendix = 1009
PART Ⅲ : U. S. TAXATION OF FOREIGN PERSONS
Chapter 11 : Foreign Persons Investing in the United States
U. S. System for Taxing Foreign Persons = 1101
Withholding on U. S.-Source Nonbusiness Income = 1102
Taxation of U. S. Real Property Interests = 1103
Appendix = 1104
Chapter 12 : Foreign Persons Doing Business in the United States
Taxation of a U. S. Trade or Business = 1201
Branch Profits Tax = 1202
Anti-earnings Stripping Provisions = 1203
Administrative Requirements = 1204
Appendix = 1205
PART Ⅳ : INTERNATIONAL TAX PRACTICE AND PROCEDURE
Chapter 13 : International Tax Practice and Procedure
International Examinations = 1301
IRS Procedural Tools = 1302
Conclusion of an Examination = 1303
Appeals Division of IRS = 1304
Competent Authority Process = 1305
Civil Actions by Taxpayers = 1306
Appendix = 1307
PART Ⅰ : BASIC PRINCIPLES
Chapter 1 : Tax Jurisdiction
Jurisdictional Issues = 101
Overview of U. S. Jurisdictional System = 102
Definition of Resident Alien = 103
Exclusion for Foreign Earned Income = 104
A Policy Note Regarding the Current U. S. System = 105
Appendix = 106
Chapter 2 : Source-of-Income Rules
Importance of Source Rules = 201
Source Rules for Gross Income = 202
Source Rules for Deductions = 203
PART Ⅱ : U.S. TAXATION OF FOREIGN INCOME
Chapter 3 : Foreign Tax Credit
Introduction = 301
Creditable Foreign Income Taxes = 302
Excess Versus Short Credit Positions = 303
Strategies for Eliminating Excess Credits = 304
Restrictions on Cross-Crediting = 305
Other Complexities of the Limitation = 306
Excess Credit Carryovers = 307
Computing the Alternative Minimum Tax Foreign Tax Credit = 308
Filing Requirements = 309
Appendix = 310
Chapter 4 : Deemed Paid Foreign Tax Credit
Taxation of Dividend Repatriations-Overview = 401
Who Can Claim a Deemed Paid Credit = 402
Computing the Deemed Paid Credit = 403
Filing Requirements = 404
Planning for Dividend Repatriations = 405
Chapter 5 : Transfer Pricing
What Is Transfer Pricing? = 501
Transfer Pricing Methods = 502
Information Reporting Requirements = 503
Transactional and Net Adjustment Penalties = 504
Developing a Transfer Pricing Strategy = 505
Chapter 6 : Anti-avoidance Provisions Governing Foreign Corporations
Subpart F = 601
Foreign Personal Holding Companies = 602
Foreign Investment and Passive Foreign Investment Companies = 603
Gain from the Sale or Exchange of a CFC's Stock = 604
Outbound Transfers to Foreign Corporations = 605
Special Rules for Noncorporate Foreign Entities = 606
Inbound Transfers from a Foreign Corporation = 607
Appendix = 608
Chapter 7 : Foreign Sales Corporations
Introduction = 701
Tax Benefits of an FSC = 702
Administrative Requirements = 703
Maximizing the FSC Benefit = 704
Interest-Charge DISCs = 705
Appendix = 706
Chapter 8 : Foreign Currency Translation and Transactions
Introduction = 801
Foreign Currency Translation = 802
Foreign Currency Transactions = 803
Chapter 9 : Tax Treaties
Introduction = 901
Common Treaty Provisions = 902
Disclosure of Treaty-Based Return Positions = 903
United States Model Income Tax Convention of September 20, 1996 = 904
Appendix = 905
Chapter 10 : Planning for Foreign Operations
Introduction = 1001
Evolution of a U. S. Exporter = 1002
Determinants of Host Country Taxation = 1003
Structuring the Foreign Operation = 1004
Basics of International Tax Planning = 1005
Comprehensive Example = 1006
Financial Reporting Implications of International Tax Planning = 1007
Survey of Foreign Entity Classification = 1008
Appendix = 1009
PART Ⅲ : U. S. TAXATION OF FOREIGN PERSONS
Chapter 11 : Foreign Persons Investing in the United States
U. S. System for Taxing Foreign Persons = 1101
Withholding on U. S.-Source Nonbusiness Income = 1102
Taxation of U. S. Real Property Interests = 1103
Appendix = 1104
Chapter 12 : Foreign Persons Doing Business in the United States
Taxation of a U. S. Trade or Business = 1201
Branch Profits Tax = 1202
Anti-earnings Stripping Provisions = 1203
Administrative Requirements = 1204
Appendix = 1205
PART Ⅳ : INTERNATIONAL TAX PRACTICE AND PROCEDURE
Chapter 13 : International Tax Practice and Procedure
International Examinations = 1301
IRS Procedural Tools = 1302
Conclusion of an Examination = 1303
Appeals Division of IRS = 1304
Competent Authority Process = 1305
Civil Actions by Taxpayers = 1306
Appendix = 1307