Tax & Accounting's Education Series

WG&L Fundamentals of International Taxation Study Problems and Instructor’s Manual Also Available Edited by Boris I. Bittker, Lawrence Lokken Updated annually Product Code: ITS7

The Best Known Reference On International Taxation For Practitioners, Especially Tailored for Professors and Students!

The 2006/2007 Edition is coming this summer, and it will cover the 2006 changes to Advance Pricing Agreements. Also, the accompanying newly revised Instructor's Manual and Study Problems are available now.

Fundamentals of International Taxation, U.S. Taxation of Foreign Income and Foreign Taxpayers, by Boris I. Bittker and Lawrence Lokken, is a for-student-use-only annual edition. It consists of 13 chapters on international income taxation from the six-volume treatise Federal Taxation of Income, Estates and Gifts, and is intended for use in a law or accounting course on the international income tax rules of the United States.

Fundamentals of International Taxation, U.S. Taxation of Foreign Income and Foreign Taxpayers synthesizes over two decades of explosive growth in the statutes and regulations covering this increasingly important area, rendering it manageable and comprehensible.

Get specific answers to questions such as:

• How do the separate basket rules, subpart F, and the rules on PFICs interrelate?
• What tax minimization opportunities were created by the check-the-box regulations and how have they been attacked since then?
• What is the current state of the regulations governing transfer pricing, withholding tax from U.S. source payments to foreign persons, and foreign currencies?

The American Jobs Creation Act of 2004 is covered, including the following:

• The repeal of the foreign personal holding company rules and the foreign investment company rules.
• The dividends-received deduction for 2005 under § 965.
• The elimination of some of the tax benefits under § 7874 associated with inversions and expatriated entities.

Table of Contents

• Introduction and Classification of Individuals and Entities
• Special Rules for U.S. Persons
• Nonresident Aliens, Foreign Corporations, and Other Foreign Persons
• U.S. Possessions
• Controlled Foreign Corporations
• Other Rules Affecting U.S. Owners of Foreign Corporations
• Transfers to and by Foreign Corporations, Export Subsidiaries, and Other Special
  Problems
• Foreign Tax Credit
• Sources of Income
• Foreign Currencies
• Reallocation of Income and Deductions Among Related Taxpayers
• Foreign Trusts and Foreign Grantors
• Specially Treated Taxpayers: Nonresident Aliens, Residents of U.S. Possessions, and Tax Motivated Expatriates

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