From the Inside Flap
A clear, concise explanation of United States tax law’s international aspects
Foreign investments in U.S. real estate and business have reached an estimated $1.8 trillion, with daily capital flows into and out of the country now exceeding $14 billion. As continuing globalization increases transactions across the U.S. border, more and more tax professionals must come to grips with international tax issues. Failure to do so may result in overlooked benefits or, even worse, inadvertent stumbles into tax pitfalls. International Applications of U.S. Income Tax Law: Inbound and Outbound Transactions provides practitioners with the understanding of tax, accounting, and legal issues necessary for operation in this special arena.
This text gives readers a practical explanation, going beyond legal terminology to clarify how rules affect taxpayers and provide incentives. In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes:
- Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate
- What a controlled foreign corporation is and what consequences result from this status
- Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles
International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Marginal tax rate analyses demonstrate the aggregate economic effects of legal rules. Empirical evidence presents tax law changes and the managerial reaction of multinational companies. Key cases and numerous examples apply points of law discussed in the text, many using foreign tax laws to illustrate application of U.S. provisions. Flowcharts, table comparisons, and exhibits help visualize major concepts.
Clearly organized and full of practical guidance for working with international tax laws, International Applications of U.S. Income Tax Law is an essential guidebook for accounting, tax, and legal practitioners in the United States or abroad.
From the Back Cover
Praise for International Applications of U.S. Income Tax Law
"Dr. Larkins has created a concise and easy-to-read summary of the essentials of international taxation. His text offers valuable insights and observations into many of the issues and topics that surface frequently in practice. The book’s practical examples and citations make it a helpful summary for the beginner as well as the more experienced practitioner."
––Steve McLeighton
Partner, International Corporate Tax Services
KPMG, LLP
"International Applications of U.S. Income Tax Law is an excellent addition to the international taxation literature. The book deals with an extremely important and complex area, and does an excellent job of making it understandable. Larkins provides an overview of the issues, a discussion of inbound and outbound transactions, and a discussion of major areas of concern in international taxation. The book also provides numerous tax planning and tax policy perspectives. International Applications of U.S. Income Tax Law is unique from other books in this area because it contains numerous examples, marginal tax rate analysis when applicable, and links to empirical studies involving issues in international taxation. It is an excellent text but also an excellent reference book."
––Thomas M. Porcano
Arthur Andersen Alumni Professor of Accountancy, Miami University
Editor of Advances in Taxation
"Larkins’s text presents all the subject areas necessary to understand the U.S. tax rules affecting foreign persons investing in the United States and U.S. persons investing overseas. The text will benefit experienced international tax practitioners as well as tax generalists seeking to learn about the international aspects of the U.S. income tax law. The illustrations are particularly useful in enabling readers to advise clients how to achieve their tax objectives and how to avoid unintended pitfalls."
––W. Theodore Kresge Jr.
Retired International Tax Partner
PricewaterhouseCoopers
"Professor Larkins provides a lucid and informative guide to the international provisions of U.S. tax law. The text is an effective learning tool in both substance and style and is equally useful for students being introduced to international tax for the first time or professionals seeking a concise reference guide."
––Gary McGill, PhD, CPA
PricewaterhouseCoopers Term Professor
University of Florida
