Taxation of International Transactions

Designed for use in law schools, business schools, and schools of management, this significantly revised casebook (formerly Gustafson, Peroni, and Pugh's Taxation of International Transactions) outlines the determination of U.S. income tax liabilities resulting from international transactions and the issues attending administration of the U.S. international tax rules. Textual discussion, cases, rulings, and problems guide students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, as well as those confronting U.S. individuals and entities seeking to derive income abroad. It covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules. This book fully covers all the significant provisions of the Tax Cuts and Jobs Act of 2017 and subsequent regulatory and administrative guidance regarding those provisions, including the revised foreign tax credit limitations, the participation exemption system in Section 245A, and the GILTI and FDII provisions.