Author Description

This book discusses one of the most complex and important areas of the federal tax the taxation by the United States of international transaction, foreign person, and foreign income. This subject, although dating back to the origins of the federal income tax system, has grown in significance in recent years as world political and economic events have led to an increasingly global economy. The basic approach of this book is to organize the entire area to provide the reader with a road map showing how the individual pieces fit together. A detailed discussion of a complex individual area is less intimidating if one knows where it fits in the overall structure. Further, we have attempted in this book to blend both academic and practical concerns. We regularly focus on the politics and theories underlying the law as it is and as it should be. At the same time, experience with real transactions and tax controversies leads us to discuss the details of the law as it now exists.