U.S. International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions - Samuel C. Thompson, Jr. cover
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U.S. International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions - Samuel C. Thompson, Jr.

by Samuel C. Thompson, Jr.

ISBN
9780890894972
Publisher
Carolina Academic Press
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$74.99 one-time purchase · 15% restocking fee on returns

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U.S. International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions Samuel C. Thompson, Jr. ISBN 9780890894972

This book examines the provisions of the Internal Revenue Code that regulate both the U.S. activities of foreign persons (inbound transactions) and the foreign activities of U.S. persons (outbound transactions).

Part I offers a foundational overview of the international tax system and explains the role and impact of tax treaties. Part II addresses the taxation of inbound transactions, including issues such as the U.S. tax treatment of branches and U.S. subsidiaries owned by foreign corporations. Part III turns to outbound transactions, focusing on the U.S. taxation of foreign corporations controlled by U.S. persons, as well as the transfer pricing rules governing transactions between commonly controlled entities, such as a U.S. parent and its foreign subsidiary. Part IV explores cross-border mergers and acquisitions, with particular emphasis on the role of Section 367 in international reorganizations.

Most chapters conclude with a brief discussion of how South Africa—following significant reforms to its international tax regime—approaches the issues under consideration. These comparative insights highlight the interaction between two sophisticated tax systems, the United States and South Africa, and underscore the importance for U.S. tax advisors of understanding how domestic rules intersect with foreign tax regimes when planning cross-border transactions.

U.S. International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions Samuel C. Thompson, Jr. ISBN 9780890894972, 978-0890894972 & 978-08908-94972

Author
Samuel C. Thompson, Jr.

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