A Practical Guide to U.S. Taxation of International Transactions

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A PRACTICAL GUIDE TO U.S. TAXATION OF INTERNATIONAL TRANSACTIONS

By Robert E Meldman and Michael S Schadewald

Published by CCH and Kluwer Law International; 499 pages

Reviewed by Deborah Sandorfy

With global commerce no longer merely an emerging area in the financial world, accountants need to be aware of the tax ramifications of international transactions. Practitioners must have access to clear and concise information about new areas they encounter or a quick reference for familiar issues. Authors Meldman and Schadewald set out to provide practitioners in the international tax arena a desk reference that provides a practical command of the tax issues and how those issues are resolved, and they have done an excellent job.

This volume essentially covers the areas of international taxation common to U.S.-based tax practice, and it is more useful as a reference guide than as a text for straight reading. The book first introduces two fundamental principles of international taxation (tax jurisdiction and source of income rules), then details various aspects of both outbound and inbound transactions. The next part deals with practice and procedure, and another section reproduces relevant IRS forms and publications and the U.S. model treaty.

The main text covers diverse topics thoroughly yet concisely, containing helpful footnotes to both the IRC and the CFR. The outbound section includes topics that are the bread and butter of expatriates, such as foreign tax credits, transfer pricing, and tax treaties; it also covers Subpart F, Planning for Foreign Operations and Currency Translation. …