U.S. International Tax Planning And Policy : Including Cross-border Mergers and Acquisitions

Table of Cases xxxiii Table of Principal Revenue Rulings and Revenue Procedures xxxv Preface xxxvii Acknowledgments xxxix Scope and Introduction 3(62) Scope and Introduction 3(3) Scope of Book 3(2) Scope of Chapter 5(1) Introduction to Present Law Taxation of Outbound and Inbound Transactions 6(6) Staff of the Joint Committee on Taxation Overview of Present-Law Rules and Economic Issues in International Taxation 6(6) Domiciliary and Source Jurisdiction 12(3) Introduction and Potential for Double Taxation 12(1) Constitutionality of U.S. Taxation of Citizens on Worldwide Income 13(1) Cook v. Tait 13(1) Questions 14(1) Exclusion for Certain Foreign Source Income of U.S. Citizens and Resident Aliens 15(1) Note on 2006 TIPRA Amendments to Section 911 16(1) Outline of Basic Statutory Provisions Governing the Taxation of Nonresident Aliens and Foreign Corporations 16(2) General Rules 16(1)