Expertise for guiding multinational business through U.S. taxation of inbound and outbound transactions, international business expansion, and transfer pricing. The insights and guidance of the world's leading international tax authorities plus the research and productivity tools you need - all on one platform. Written by leading practitioners in the field, the Foreign Income Portfolios provide everything necessary to research, plan, and implement strategies to streamline compliance while minimizing clients’ exposure to taxes.

Expert Analysis

Written by leading tax authorities, nearly 100 Portfolios provide practical analysis in virtually any scenario involving U.S. taxation of cross-border transactions transactions — from foreign tax credits and branch profits tax to foreign partners and partnerships and Subpart F Corporations. In addition to topic-specific guidance, you get specific technical information necessary to manage business expansion and operations in 40 countries. Portfolios are organized as follows::

• U.S. Taxation of International Transactions: “Outbound” (U.S. Business Investing Overseas); “Inbound” (Foreign Business Investing in the U.S.); Rules That Apply to Both Types of Transactions
• Transfer Pricing: U.S. Transfer Pricing Rules and Economic Principles Transfer Pricing Rules of 14 Major Foreign Countries
• Country Portfolios: 40 country-specific Portfolios covering the basic business and tax requirements involved in operating a business in a particular country, including Puerto Rico
• U.S. Tax Overview: This introduces the researcher to the U.S. federal tax system, including procedural aspects. The major focus is on income taxation, including the rules covering individuals, corporations, partnerships, estates, and trusts, plus alternative minimum tax.

Practice Tools

• Federal Tax Calendar
• Interactive Federal tax forms
• Tables, charts, and lists
• Working Papers: Sample elections, Sample filled-in forms

Source Documents

• Full text of the IRC
• Final, Temporary, and Proposed Regulations
• IRS Documents - including Revenue Rulings, Revenue Procedures, Notices and Announcements, PLRs and TAMs, CCAs, FSAs, and SCAs
• IRS Publications
• Treasury regulations and decision preambles
• Full Text of Federal Cases from all federal courts from 1913 to date; Tax court rules; Court of Federal Claims Rules
• Selected full text of legislation with committee reports
• Circular 230
• Coordinated Issue Papers/Industry Specialization Papers — 2000-Present
• Tax Treaties —  full text of treaties between the US and foreign countries.
• New! Archived versions of the Internal Revenue Code (IRC) - as far back as the year 2000

News & Commentary

• Daily Tax Highlights — Daily highlights from each issue of the Daily Tax Report, covering key legislative, regulatory, and legal tax developments. 
• Tax and Accounting Memorandum — An authoritative outlook, including commentary from Bloomberg BNA’s Advisory Boards, on new issues, developments, trends, and strategies. 
• Weekly Report — Timely notification of tax-related legislative, judicial and regulatory developments. 
• Insights & Commentary — Commentary by leading authorities on a variety of current and emerging tax issues. 
• International Journal — Expert monthly commentary on U.S. inbound and outbound tax developments (including major regulatory projects), cross-border perspective from Canada and Mexico, and status of U.S. tax treaties. 
• Transfer Pricing Report (optional) — Practical service providing news and analysis on U.S. and other governments’ tax policies regarding intercompany transfer pricing and helps companies structure their operations to avoid double taxation.

Provisions Applicable to U.S. and Foreign Persons

Aliens Who Invest the United States Through a Low-Tax Jurisdiction (Portfolio 944)

The Allocation and Apportionment of Deductions (Portfolio 906)

Bilateral Transfer Tax Treaties (Portfolio 939)

The Creditability of Foreign Taxes — General Issues (Portfolio 901)

The Foreign Tax Credit Limitation Under Section 904 (Portfolio 904)

Foundations of U.S. International Taxation (Portfolio 900)

Indirect Foreign Tax Credits (Portfolio 902)

International Aspects of U.S. Social Security and Unemployment Taxes (Portfolio 917)

International Aspects of U.S. Withholding on Wages and Service Fees (Portfolio 916)

Other Transfers Under Section 367 (Portfolio 920)

Reporting Requirements Under the Code for International Transactions (Portfolio 947)

Source of Income Rules (Portfolio 905)

U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941)   

U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936)

Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940)

U.S. Income Taxation of International Insurance Activities(Portfolio 931)  

U.S. Tax-Related Accounting Issues of Multinational Corporations (Portfolio 948)

U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945)

Outbound Transfers Under Section 367a (Portfolio 919)

Taxation of Foreign Persons' U.S. Income

The Branch-Related Taxes of Section 884 (Portfolio 909)

Federal Taxation of Foreign Investment U.S. Real Estate (Portfolio 912)

Partners and Partnerships — International Tax Aspects (Portfolio 910)

U.S. Income Taxation of Foreign Corporations (Portfolio 908)

U.S. Income Taxation of Foreign Governments, International Organizations and Their Employees (Portfolio 913)

U.S. Income Taxation of Foreign Students, Teachers, and Researchers (Portfolio 914)

U.S. Income Taxation of Nonresident Alien Individuals (Portfolio 907)

U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911)

U.S. Withholding and Reporting Requirements for Payments of U.S. Source Income to Foreign Persons (Portfolio 915)

Taxation of U.S. Persons' Foreign Income

CFCs — Foreign Base Company Income Other than FPHCI (Portfolio 928)

CFCs — Foreign Personal Holding Company Income (Portfolio 927)

CFCs — Sections 959-965 and 1248 (Portfolio 930)

Controlled Foreign Corporations — Section 956 (Portfolio 929)

Export Tax Incentives (Portfolio 934)