This book provides law teachers with a relatively simple, easy to use casebook to teach U.S. international taxation. The field is notoriously complex, more so, perhaps, than any other area of Federal tax law. The focus is on how the details of the tax law fit into a broader structure, which is described in the introduction. Enables students to fit the particular issues they are working on into a larger context, to develop an intuition for where the problem areas may lie. This new edition is updated to reflect numerous changes in the law since the second edition, including new provisions enacted in August 2010.

Imprint: Foundation Press
Series: University Casebook Series
Publication Date: 11/30/2010


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The 2010 edition includes the following new elements and updates:

Review Problems:

  • The addition of review problems at the end of every chapter for students to use as an evaluative tool.
Statutes: Significant statutory changes, including:
  • August 2010 statutory changes to the U.S. source rules
  • Multiple August 2010 statutory changes to the foreign tax credit rules
Important New Cases and Rulings:
  • Container Corp. v. Commissioner (2010)
  • Veritas v. Commissioner (2009)
  • 2009 General Legal Advice  on Permanent Establishments(IRS)
Important Regulatory Changes:
  • Introduction of new cost sharing regulations in transfer pricing
  • New final regulations for transfer pricing of services
  • Regulations under the 2006 statutory changes to A reorganizations
Treaty Developments:
  • New U.S. Model Treaty
  • Impact of Recent UBS case on exchange of information

Learn more about this series.