International Applications of U.S. Income Tax Law Inbound and Outbound Transactions

A clear, concise explanation of United States tax law’s international aspects

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.

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Ernest R. Larkins is the E. Harold Stokes/KPMG Professor of Accounting at Georgia State University, where he teaches graduate courses in federal tax research and international taxation. He has published approximately 100 articles in various academic, law, and professional journals, as well as several chapters in books and monographs. He has received research fellowships from the Australian Taxation Studies Program (ATAX), University of New South Wales, and, for work conducted in Russia, the Society of International Business Fellows. He is an active member of the American Accounting Association and the American Taxation Association.