A carefully balanced approach to US income taxation intended for the non-US professional or student with a background in basic concepts of income taxation. It explains in plain language the complexities of the US tax system, often by comparison and contrast with European and other national tax systems.
The use of highly technical language has been avoided in consideration to those readers for whom English is their second language. Sufficient detail is incorporated to answer most primary questions about what makes the US tax system work.
Topics covered include the individual and corporate income taxes, partnership taxation, special types of taxpayers (pensions, Subchapter S corporations) and the underlying ‘unwritten law' of US taxation.
Special emphasis is placed on the international rules, particularly inbound business, sales and investment. Broad coverage is given to the anti-avoidance rules which contribute to the US tax system's comlexity (e.g. Subpart F, FIRPTA and transfer pricing). References to the Internal Revenue Code, Treasury Regulations and major rulings are included for those practitioners who wish to pursue a thought or idea to the next level.