Where there's trade, there's taxation. And more often than not these days, that means United States taxation. This book clearly explains basic structural features and accounting issues, corporate and partnership taxation, and the rules governing international transactions, both inbound and outbound. It provides concise answers to such questions as: what is the US tax treatment of mergers and acqusitions?; how are joint ventures and other hybrid entities taxed in the United States?; how does the US foreign tax credit work?; what are the most tax-beneficial ways to form a business in the United States?; and how can special profit and loss allocations under US partnership law be used in international transactions? It helps to provide a clear "picture" of the US tax system, yet the book is also of great value as a quick reference when a US tax problem needs to be solved.

The US Treasury Department's draft Model Income Tax Convention, published in 1981 (the 1981 Model), was withdrawn as the official US Model in 1992. This monograph contains an article-by-article, paragraph-by-paragraph analysis of the new 1996 US Model Tax Convention. Each paragraph is compared with any corresponding provisions in the 1981 US Tax convention and the 1995 OECD Model Convention. In addition, the technical explanation accompanying the new 1996 US Model is discussed and analyzed. The 1996 US Model not only offers insight into the Treasury's negotiating position with respect to future tax treaties, but also provides insight into Treasury's interpretation of existing treaties that employ language similar to that in the new US Model.