4. The Split of Tax Jurisdiction: The Source Rules
5. The US Taxing Regime of Foreign Taxpayers
6. The Branch Profits Tax
7. Foreign Investment in Real Property Transaction Act
8. The Taxation of Foreign Sovereign in the United States
9. The International Tax Treaty Rules
10. Foreign Account Tax Compliance Act
11. Taxation Regime of Expatriates and Corporate Inversion
12. The Investments of US Individuals or Corporations Abroad
13. The US Foreign Tax Credit Regime
14. The Subpart F Regime
15. Taxation of Derivatives
16. The Taxation of Foreign Currency
17. Domestic International Sales Corporation
18. International Outbound Transactions
19. Cross-Border Tax Arbitrage
20. Base Erosion and Profit Shiftingdiv>
Felix I. Lessambo is Adjunct Associate Professor at the Peter J. Tobin College of Business at St. John's University, USA. He practiced in international tax and alternative investment management groups where he structured and advised on hedge funds and private equity cross-border transactions. He is the author of several books in finance, including The International Banking System,The International Corporate Governance System, and International Financial Institutions and Their Challenges.
This book covers a broad range of the most challenging topics in US international taxation laws before breaking into separate discussions of the issues related to both inbound and outbound taxes. Real examples and selected seminal cases are analysed at the end of each chapter to simplify even the most abstract tax provisions. Practitioners, academics, and advanced students specializing in specific areas of international finance will welcome this comprehensive overview of the US tax system's international laws.