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Georgetown Law Library

International and Foreign Tax Law Research Guide

This guide is a starting point for research on international and foreign tax law research.

International Taxation -- U.S. Law & Practice

The treatises and practice guides described below provide in-depth coverage of U.S. law and practice with respect to international taxation.  To locate additional resources, search GULLiver, the Law Library's online catalog by keyword or by title.  Or search by subject, using one of the following subject headings:

Electronic Resources

Practical Guide to U.S. Taxation of International Transactions. (CCH)
Part I provides an overview of the U.S. international tax system, including jurisdictional and source-of-income rules.  Part II covers U.S. taxation of the foreign activities U.S. citizens and residents.  Part III covers U.S. taxation of the domestic activities of foreign persons.  Part IV covers transfer pricing, tax treaties, and cross-border mergers.

Rhoades & Langer U.S. International Taxation and Tax Treaties. 
Parts I and II cover U.S. international tax law and practice.  Part III covers U.S. income tax treaties.  Part IV covers other types of U.S. tax treaties.  Appendix A includes the full texts of all U.S. tax treaties currently in force.

Kuntz & Peroni:  U.S. International Taxation. 
Analyzes the treatment of U.S. taxpayers with foreign income or activities, as well as the treatment of foreign taxpayers with U.S. income or activities.  Also available on Checkpoint.  (Select International Tax as the practice area. Then click on the + sign next to WG&L Treatises under Editorial Materials.)

Levey:  U.S. Taxation of Foreign-Controlled Businesses.
Covers both inbound transactions involving foreign businesses operating in the U.S., as well as outbound transactions involving U.S. businesses operating in select foreign jurisdictions.  Also available on Checkpoint.  (Select International Tax as the practice area. Then click on the + sign next to WG&L Treatises under Editorial Materials.)

Lowell & Martin:  U.S. Int'l Taxation:  Practice & Procedure.
Provides step-by-step advice on handling IRS international examinations, from information document requests to the preparation of protests and alternative dispute submissions, plus extensive commentary.  Also available on Checkpoint.  (Select International Tax as the practice area. Then click on the + sign next to WG&L Treatises under Editorial Materials.)

Lowell & Martin:  U.S. International Transfer Pricing. 
Describes the substantive law and offers advice on how to draft transfer pricing agreements and respond to IRS challenges.  Also available on Checkpoint. (Select International Tax as the practice area.  Then click on the + sign next to WG&L Treatises under Editorial Materials.) 

Print Sources