CCH Expert Treatise Library: International Taxation: Corporate and Individual


Get up-to-date, comprehensive expert treatise guidance related to the United States taxations of foreign persons and foreign income.

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The Basics:

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The CCH Expert Treatise Library: International Taxation: Corporate and Individual covers material relating to outbound investments, inbound investments and tax treaties. Authored by Phillip Postlewaite, this concise treatise discusses in detail the international tax consequences, from a United States perspective, of transactions carried out by individuals, partnerships, and corporations, as well as those occurring between partnerships and corporations and their owners.

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Features:

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CCH Expert Treatise Library: International Taxation: Corporate and Individual brings together a variety of helpful features that help you effectively manage complex issues and provide accurate tax planning.

  • Provides a comprehensive perspective from a world-renowned expert: Author Philip Postlewaite, BBA, JD, LLM, Harry Horrow Professor in International Law at Northwestern University School of Law, is an expert in the area of tax law and has taught courses in individual, corporate, partnership and international taxation. He is the author or coauthor of more than 30 books and 30 articles.
  • Comprehensive coverage: The treatise covers a variety of transactions, and the international tax implications, carried out by individuals, partnerships, and corporations, as well as those occurring between partnerships and corporations and their owners. Users benefit from its timely, thorough, and practical references.
  • Access to supporting documentation: Links to IRS Code and Regulations, Private Letter Rulings, Revenue Rulings, Technical Advice Memoranda, General Counsel Memoranda and more.

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The Content:

 

International Taxation: Corporate and Individual by Philip F. Postlewaite has been broken down into two separate volumes – outbound and inbound.

Volume 1: Outbound Topics

  • Residency
  • Source Rules
  • The §911 Exclusion: Taxation of United States Citizens Working Abroad
  • Export Sales
  • Tax Treaties
  • Foreign Tax Credit
  • Controlled Foreign Corporations
  • Passive Foreign Investment Companies and Other Anti-Deferral Measures
  • Section 367: Outbound Transfers of Property
  • Section 482: International Transactions Among Related Parties – Outbound
  • International Partnerships and Partners – Outbound Considerations

Volume 2: Inbound Topics

  • Tax Treaties – An Overview
  • Tax Treaties and Business Income
  • Tax Treaties and Passive Income
  • Non-Residency
  • Source Rules
  • Trade or Business Status
  • Taxation of Foreign Persons
  • Dispositions of Investments in United States Real Property
  • Section 367: Inbound Transfers of Property
  • Section 482: International Transactions Among Related Parties – Inbound
  • International Partnerships and Partners – Inbound Considerations

Practice Aids:

  • US Model Income Tax Treaty of 2006
  • U.S. Model Technical Explanation Accompanying the US. Model Income Tax Treaty of2006
  • Treaty between the U.S. and Canada
  • Treasury Department Technical Explanation of the Treaty between the US and Canada
  • Treasury Department Technical Explanation of the 2007 Protocol Amending the Treaty between the US and Canada

Access to Primary Source Documents, Topical Index and Table of Cases

  • Laws
  • Regulations
  • IRS Rulings and Procedures
  • Private Letter Rulings
  • Technical Advice Memoranda
  • General Counsel Memoranda
  • Notices
  • Tables of Cases
  • Comprehensive Topical Index

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The Benefits:

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The CCH Expert Treatise Library: International Taxation: Corporate and Individual will allow you to:

  • Assess the impact on your business or your clients’ businesses to make informed decisions.
  • Provide practical advice to business partners or clients.
  • Quickly find accurate answers to your international taxation questions via easy-to-understand explanations.
  • Find answers that reflect the realities of actual tax practice instead of theoretical tax research.
  • Access answers seamlessly through integrated tax links.

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