Practical Guide to U.S. Taxation of International Transactions

Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

Michael S. Schadewald, Ph.D., CPA, is on the faculty of the University of Wisconsin-Milwaukee, where he teaches graduate courses in multistate and international taxation. A graduate of the University of Minnesota, Professor Schadewald is a co-author of several books on multistate and international taxation, and has published more than 30 articles in academic and professional journals, including the CPA Journal, Journal of Taxation, The Tax Adviser, TAXES: The Tax Magazine, International Tax Journal, International Tax Notes, and Journal of International Accounting, Auditing and Taxation. Professor Schadewald has also served on the editorial boards of Journal of the American Taxation Association, International Journal of Accounting, International Tax Journal, Issues in Accounting Education, and Journal of Accounting Education. Robert J. Misey, Jr., J.D., LL.M., M.B.A., is a shareholder in the law firm of Reinhart, Boerner, Van Deuren s.c. in Milwaukee. Mr. Misey focuses his practice in the areas of international taxation, transfer pricing, and tax controversies. He previously worked as an attorney for the IRS seving with the IRS Chief Counsel (International) in Washington D.C. and as a large-case attorney in the Western and Southeast Regions. He also worked as a member of Deliotte & Touche's International Tax Services Group and has tried 23 cases before the U.S. Tax Court. He is a member of the Tax Section of the District of Columbia, California and Wisconsin Bars. He has written numerous articles on tax issues and has spoken at continuing education programs on tax as well. He is the author of CCH's "ETI Repeal Under the American Jobs Creation Act of 2004: Analysis of the Law's Impact on U.S. Business."