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This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions; Part III focuses on outbound transactions; and Part IV focuses on cross-border mergers, acquisitions and joint ventures. The last sections of most chapters briefly discuss the manner in which South Africa, which has recently reformed its international tax system, addresses the issues presented in the chapter. From a tax planning standpoint, the U.S. tax advisor should have a basic understanding of the interface between the U.S. and foreign tax system involved in the transaction, and these discussions illustrate the interface between two sophisticated systems.
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Samuel C. Thompson, Jr. is a professor of law at the University of California at Los Angeles School of Law.
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Book Description Carolina Academic Press, 2007. Hardcover. Condition: New. Never used!. Seller Inventory # P110890894973
Book Description Carolina Academic Press. Condition: New. Hardcover. Worldwide shipping. FREE fast shipping inside USA (express 2-3 day delivery also available). Tracking service included. Ships from United States of America. Seller Inventory # 0890894973
Book Description Carolina Academic Press, 2007. Hardcover. Condition: New. Seller Inventory # DADAX0890894973
Book Description Carolina Academic Pr, 2007. Hardcover. Condition: Brand New. 644 pages. 10.00x7.25x1.50 inches. In Stock. Seller Inventory # 0890894973