U.S. taxation of international transactions, with an emphasis on essential areas that businesses and their financial advisors need to understand. The Fifth Edition is substantially a new book because it is completely revised and reorganized to reflect the current state of U.S. international tax law after passage of the American Jobs Creation Act of 2004. It covers the repeal of the extra-territorial income (ETI) regime and its replacement by the domestic production deduction, the new temporary dividends-received deduction, modifications to the foreign tax credit, changes to the anti-deferral regimes, the tightening of tax rules on expatriation of individuals, and a number of other important changes. Even with increased coverage and substantial reorganization, the book maintains its initial mission of providing a well-written and concise explanation of this increasingly important subject that is accessible to all those who toil over U.S. international tax issues. This classic text was developed to shed light on the U.S. rules in a way that all practitioners and students of U.S. international tax can understand and apply. It's the one book that can be found in the libraries of both sophisticated U.S. international tax experts, as well as small firm general practitioners working with a clients who are just getting involved in doing business beyond U.S. borders.

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