International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions
From the publisher: "This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions and addresses such issues as the U.S. taxation of a branch or U.S. subsidiary owned by a foreign corporation. Part III considers outbound transactions and deals with the U.S. taxation of foreign corporations controlled by U.S. persons. This part also addresses the rules regarding transfer pricing between commonly controlled entities, such as a U.S. parent corporation and its foreign subsidiary. Part IV focuses on cross-border mergers and acquisitions. Particular attention is given to the role of Section 367 on cross border reorganizations."
Carolina Academic Press
Thompson, Samuel C. Jr., "International Tax Planning and Policy: Including Cross-Border Mergers and Acquisitions" (2007). Books. 18.