INTERNATIONAL TAXATION: US TAXATION OF FOREIGN PERSONS AND FOREIGN INCOME (2026)

International Taxation is a comprehensive treatise written by Bret Wells, Professor of Law at the University of Houston Law Center, and Joseph Isenbergh, emeritus Professor of Law at the University of Chicago. It provides in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies. Exploring the labyrinth of international tax law in a compelling and illuminating way, the book fosters a new level of understanding and appreciation of the law for all tax practitioners.

International Taxation guides all those who face international tax questions and provides superlative commentary for those who must delve into the sprawling and amorphous assemblage of laws and regulation in this area.

It shows the practitioner how to:

• Structure international corporate transactions for maximum benefit.
• Minimize liability under applicable laws and treaties.
• Practice effectively and compliantly within the complex web of legal authority

The book includes over 100 distinct chapters that effectively present material in digestible amounts for the reader. It is organized in the following Eight Parts:

1. Part I Elements of International Taxation
2. Part II U.S. Taxation of Nonresident Aliens and Foreign Corporations
3. Part III U.S. Taxation of Foreign Income
4. Part IV Foreign Currency Questions
5. Part V International Corporate Reorganizations
6. Part VI Income Tax Treaties
7. Part VII Withholding in International Taxation
8. Part VIII International Transfer Taxation
9. Detailed footnotes, finding lists, a topical index help readers reference authority and facilitate additional research.
     

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