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Library of Congress Cataloging-in-Publication Data:
Larkins, Ernest R. (Ernest Radford)
International applications of U.S. income tax law : inbound and outbound transactions /
by Ernest R. Larkins.
p. cm.
Includes index.
ISBN 0-471-46449-X (cloth : acid-free paper)
1. Income tax—United States—Foreign income. 2. Investments, Foreign—Taxation—
Law and legislation—United States. 3. Aliens—Taxation—Law and legislation—United
States. 4. Foreign tax credit—United States. 5. Double taxation—United States.
I. Title: International applications of US income tax law. II. Title.
KF6419.L37 2004
343.7305′248—dc21
2003014219
Printed in the United States of America
10 9 8 7 6 5 4 3 2 1
4133 P-00(FM) 9/11/03 2:27 PM Page iv
My wife, Nancy, has acted as cheerleader (and unofficial press
agent) throughout the process. She has my appreciation for her
confidence and enthusiasm. I dedicate this text to the three people
I have enjoyed teaching the most—my own children—Joshua,
Esther, and Hannah. I also thank the many Georgia State
University students who have taken my international tax class,
and wish them well in their lives and careers.
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