United States Income Tax Treaties

With domestic tax shelters legislated out of existence, international transactions of all types will receive closer scrutiny than ever. In this tough climate, knowing what the Internal Revenue Service teaches its own examiners to look for when reviewing international tax cases could prove the ultimate weapon. These materials uniquely position the user to be privy to this insightful information. The three-volume set, totaling 2,400 pages, comprises course work designed by agents of the Internal Revenue Service (IRS) as its own instructional material. This information does not appear in the IRS Manual; nor is it available from the U.S. Government Printing Office. The publication offers such unparalleled practical features as step-by-step 'audit techniques', descriptions of many procedural steps underlying tax audits, & a specially prepared index which provides easy access to specific subjects & issues. Subjects covered include source of income, taxation of foreign corporations doing business in the United States, withholding of tax at source on non-resident aliens & foreign corporations, tax treaties, IRC Section 897 disposition of investment in U.S. real property, earnings & profits, foreign tax credit, IRC Section 482, controlled foreign corporation, investment of earnings in U.S. property by a CFC, Treas. Reg. Section 861-8, foreign currency exchange gains & losses, captive offshore insurance company, financial arrangements through an international finance subsidiary, taxation of aliens, & taxation of U.S. citizens abroad. Its unmatched, behind-the-scenes information makes this resource essential for in-house advisers, attorneys, tax consultants, & accountants dealing with international tax issues. Update frequency: 1-2 supplements a year.Vogel, Klaus is the author of 'United States Income Tax Treaties', published 1990 under ISBN 9789065449696 and ISBN 9065449698.