Taxation of International Transactions: Materials, Text, and Problems

Robert J. Peroni, University of Texas School of Law

Karen B. Brown, George Washington University Law School

J. Clifton Fleming Jr., Brigham Young University Law School

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Table of Contents

2025 Update Memo

Draft Teacher's Manual

1. Discusses the many changes made by the 2017 Act and the regulations interpreting those changes:

a. Section 245A deduction, which implements a new participation exemption system;

b. New GILTI inclusion provisions in Section 951A of Subpart F;

c. Substantially revised foreign tax credit system, including the repeal of the Section 902 indirect credit, the substantial revision of the Section 960 indirect credit, and the addition of two new basket limitations in Section 904(d) for Section 951A GILTI inclusions and foreign branch income;

d. New source rules for manufactured inventory in Section 863(b) and the regulations issued under that provision;

e. New FDII export tax incentive in Section 250 and the relative advantages and disadvantages of using foreign business vehicles to conduct export operations;

f. New BEAT provisions in Section 59A;

g. New interest deduction limitations in Section 163(j);

h. New branch loss recapture rules;

i. Repeal of a major exception to gain recognition in outbound corporate transfers and the connection to increased adverse consequences for corporate expatriations; and

j. Related party hybrid transactions.

2. Incorporates throughout the book a discussion of the 2016 U.S. Treasury Model Treaty and the most recent version of the OECD Model Treaty.

3. Discusses recent court decisions and revenue rulings and revenue procedures.

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