This Nutshell, which provides an introduction to U.S. international taxation useful to both U.S. and non-U.S. students and practitioners interested in the topic, has been revised and updated to reflect the passage of the One Big Beautiful Bill Act passed in July 2025, along with other regulatory developments and recent court decisions. It also includes a discussion of developments in the tax rules as applied to new technologies, including crypto and digital. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In addition to providing a survey of the technical rules, the book also offers insight into tax planning considerations and how these have been impacted by U.S. and global developments. Referenced throughout are recent global tax developments and how OECD and UN rules and proposals interact with the U.S. international tax regime. In today’s world, it is crucial for those involved in business and investment activities to understand the tax consequences of cross-border flows. The book has been updated with a new chapter on non-income taxes as they affect cross-border trade, including the intersection of the income tax rules and the tariffs. The author’s career spans the academic and private sectors, and she has used her experiences to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts.


Imprint: West Academic Publishing
Series: Nutshells
Publication Date: 01/02/2026

Mindy Herzfeld, University of Florida College of Law

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  • Updated to reflect law changes introduced by OBBB to the international tax rules
  • Updated for changes to regulations since 2022, including foreign tax credit, PTEP, and foreign currency rules
  • Updated to reflect developments in taxation of crypto and digital technology
  • New chapter added on non-income taxes that impact cross-border investment and trade, including tariffs, remittance tax, stock buyback excise tax, and estate and gift transfer taxes

Learn more about this series.