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 from the Georgetown Law Library's collection, use the Advanced Search and select Law Library Catalog. For greater precision, search by subject using one of the following subject headings:
Basics of International Taxation (2024)
Published annually by the Practicing Law Institute (PLI), this practitioner-oriented resource provides an overview of U.S. rules and regulations that govern international taxation, highlighting key developments and changes during the past year.
Bloomberg BNA U.S. International Tax Portfolios
These practitioner-oriented portfolios cover the taxation of foreign persons' U.S. income, the taxation of U.S. persons' foreign income, and U.S. tax law provisions applicable to both U.S. and foreign persons. To search by keyword across all portfolios, enter words or phrases in the search box at the top of the page. To browse, select a topic and click on the + sign to the left to expand the browsing menu.
Bloomberg BNA Transfer Pricing Portfolios
These practitioner-oriented portfolios cover transfer pricing rules and practices in the U.S. (Portfolio 886 and Portfolios 6904-6938) and in more than two dozen jurisdictions outside the U.S. (Portfolios 6940-6975).
International Estate & Tax Planning (2024)
Published annually by the Practicing Law Institute (PLI), this handbook provides practical advice on U.S. tax planning for individuals arriving in or leaving the U.S.; structuring foreign investments in U.S. real estate; U.S. tax planning for foreign inbound grantor and non-grantor trusts; international information reporting requirements and unreported foreign income; as well as anti-money laundering provisions and ethical issues.
International Tax Controversies: A Practical Guide (2024)
Published annually by the Practicing Law Institute (PLI), this treatise provides a detailed roadmap on how to prepare for tax audit involving a cross-boarder transaction. It also covers when the mutual agreement procedures (MAPs) of a tax treaty many be invoked to resolve a conflict between the U.S. Internal Revenue Service and a tax authority in another jurisdiction. Such conflicts often arise over transfer pricing issues and may be avoided by the use of an advanced pricing agreement (APA).
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 Checkpoint. (Select International Tax as the practice area. Then click on the + sign next to WG&L Treatises under Editorial Materials.)
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.
International Taxation: Corporate and Individual (10th ed.)