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Aspen Treatise for Introduction to United States International Taxation, Seventh Edition

Authors
  • James R. Repetti
  • Diane M. Ring
  • Stephen E. Shay
Series / Aspen Treatise Series
Teaching Materials
NO
Description

The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the U.S. and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the United States in taxing American or foreign individuals and corporations as they invest, work, or carry on a trade or business in the U.S. or abroad. Throughout the book, the authors incorporate references not only to the Internal Revenue Code provisions under discussion, but also to relevant Treasury Regulations, other administrative material, and important cases that have arisen. For tax practitioners, tax professors, and students both within and outside the U.S., and others seeking a structural framework in which an international tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.

The 7th Edition focuses on:

  • General aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects
  • The basic jurisdictional principles adopted by the U.S. with respect to application of income tax to international investment and business transactions
  • The rules for taxing foreign corporations, foreign partnerships, foreign trusts, and non-resident aliens on their business and investment income derived from U.S. sources
  • The basic mechanism adopted by the U.S. to alleviate international double taxation on foreign source income derived by U.S. sources
  • The income tax treatment of foreign corporations controlled by U.S. shareholders, including the new GILTI minimum tax and exempt dividend rules
  • The special treatment under FDII of a U.S. corporation’s export of goods, services, and intangible rights
  • The general inter-company pricing rules and special transfer pricing rules applicable to particular transactions Rules for the treatment of transactions involving currencies other than the U.S. dollar
  • Situations in which U.S. income tax treaty provisions modify the basic rules The wealth transfer tax system, including modifications made by estate and gift tax treaties
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About the authors
Diane Ring
Professor of Law
Boston College Law School

Diane M. Ring is a Professor of Law at Boston College Law School, where she researches and writes primarily in the field of international taxation, corporate taxation, and ethical issues in tax practice. Her recent work addresses issues including information exchange, international tax relations, advance pricing agreements, and ethics in international tax. Ms. Ring was a consultant for the United Nations 2013 project on treaty administration for developing countries. She was the U.S. National Reporter for the 2012 IFA Conference on the Debt Equity Conundrum, and the U.S. National Reporter for the 2004 IFA Conference on Double Nontaxation. She was the Assistant General Reporter for the 1995 IFA Conference on Financial Instruments and was a consultant to the IFA research project on the impact of technological and financial innovation on the taxation of income and activities. Ms. Ring is also co-author of three case books in taxation—one on corporate taxation, one on international taxation, and one on ethical problems in federal tax practice.

Prior to joining Boston College Law School, Ms. Ring was an associate professor of law at the University of Florida Levin College of Law, and an assistant professor at Harvard Law School. Before entering academia, Ms. Ring practiced at the firm of Caplin Drysdale in Washington, D.C., specializing in the area of international tax and the taxation of financial instruments. Ms. Ring also clerked for Judge Jon O. Newman of the Second Circuit Court of Appeals.

Product Information
Edition
Seventh Edition
Publication date
2022-06-01
Copyright Year
2022
Pages
256
Paperback
9781543810806
Connected eBook (Digital Only)
9798889065463
Subject
Taxation, Elective
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