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U.S. Tax Guide

International Corporate Taxation

Information provided on this site is for general guidance only and is often simplified. Actual IRS procedures are complex, and taxpayers should obtain professional assistance or use IRS sources for complete information.

International Corporate Taxation

The taxation of U.S. companies doing business internationally, and foreign companies doing business in the U.S.. The use of tax treaties, and a comprehensive study of U.S. rules for transfer pricing. A study of how the Foreign Sales Corporation export tax breaks turned into a bonanza for repatriating foreign profits.

U.S. Companies Internationally
An analysis of the legal and taxation characteristics of legal forms for doing business outside the U.S.A.
International Business Structures and their Tax Treatment »
President Obama's Plans to Change International Business Taxation »

Foreign Companies in the U.S.
The basis of U.S. taxation of foreign companies and their U.S. shareholders.
Foreign Corporations »
Foreign-Controlled U.S. Corporations »
Partnerships »

Foreign Sales Corporations
The export tax breaks which were banned by the World Trade Organization but have come back to life in new legislation.
Foreign Sales Corporations »
Extra-Territorial Income Exclusion Act »
Remedial U.S. Legislation »

American Jobs Creation Act of 2004
The American Jobs Creation Act may or may not have created many jobs, but it has seen U.S.$300bn repatriated almost tax-free.
American Jobs Creation Act of 2004 »
Results of the A.C.J.A. »
Resolution of the E.U.'s Complaint »

Double Tax Treaties
Without tax treaties, international investment would be even more of a tax nightmare than it already is.
U.S. Double Tax Treaties »
Table of Tax Treaties »
Recent Developments in U.S. Tax Treaties »
Dividend Taxation under 2003 Tax-Cutting Legislation »
Tax Information Exchange Agreements »

Transfer Pricing
An extensive analysis of the U.S. system of arm's length pricing for international transactions.
The U.S. Transfer Pricing Regime »

Tax Filing
A brief guide to the forms you have to file in various corporate situations.
Foreign Corporations
Foreign Companies in the U.S. – Partnerships »
Foreign-Controlled Corporations »
Controlled Foreign Corporations »
D.I.S.C. »

Delaware Tax Guide

More than half of the Fortune 500 companies are incorporated in Delaware as a result of its favorable tax regimes.

View our Delaware section

U.S. Tax Treaty Developments

Treaty Update: Liechtenstein - United States
28 March, 2018
Liechtenstein and the United States are newly engaged in negotiations towards a DTA.
Treaty Update: United States - Armenia
20 February, 2018
US Treasury Secretary Steven Mnuchin on February 6, 2018, agreed to pursue DTA negotiations with Armenia.
Treaty Update: Taiwan - United States
11 January, 2018
Taiwanese Premier Lai Ching-Te has directed the Ministry of Finance to work towards a Taiwan-US tax treaty.
Treaty Update: Vietnam - United States
07 March, 2017
According to recent media reports, Vietnam will soon ratify its new DTA with the United States.
Treaty Update: United States - Argentina
12 October, 2016
Speaking on September 26, US Treasury Secretary Jack Lew disclosed that the US and Argentina are to negotiate a comprehensive double taxation agreement.