Foundations of International Income Taxation

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This law school casebook extracts materials from scholarly literature on international income tax law and provides context for these materials, to enhance an understanding of the institutions that shape this area of law and underlying policy debates. Designed for use as a principal text, it may also be used as supplemental reading, with topics assigned as they are taken up in the course or assigned or recommended to students to read on their own.
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Product Details

  • ISBN-13: 9781587785153
  • Publisher: West Academic Publishing
  • Publication date: 10/1/2003
  • Series: Foundations of Law
  • Edition description: New Edition
  • Pages: 541
  • Product dimensions: 6.50 (w) x 9.90 (h) x 1.10 (d)

Table of Contents

Introduction and Overview1.1. Introduction 1.2. Taxation Based on Residence Versus Source 1.3. Worldwide Versus Territorial Taxation 1.4. The Key Normative Concepts of International Tax Policy Source of Income 2.1. Introduction 2.2. U.S. Source Rules 2.3. Potential Objectives of Source Rules 2.4. The Unraveling of Current U.S. Source Rules and the Erosion of U.S. Source Taxation 2.5. Double Taxation under the Current Source Rules 2.6. Formulary Apportionment as a Potential Response Residence 3.1. Introduction 3.2. Determination of Individual Residence 3.3. Advantages of Residency-Based Taxation 3.4. The Special Problems of Students, Actors and Professional Athletes 3.5. Expatriation By Individuals 3.6. Determination of Corporate Residence 3.7. Corporate Expatriation and Inversions 3.8. Electronic Commerce 3.9. Treaty Shopping 3.10. Tax Arbitrage: Dual Residence The Foreign Tax Credit 4.1. Introduction 4.2. Origins of the Foreign Tax Credit and the Foreign Tax Credit Limitation 4.3. Mechanics and Structural Problems 4.4. Policy Directions Deferral and Controlled Foreign Corporations 5.1. Introduction 5.2. History and Overview of Subpart F 5.3. Subpart F and other Anti-Deferral Regimes 5.4. The Contemporary Policy Debate over Deferral 5.5. Proposed Reforms to Subpart F 5.6. An Exemption of Foreign Source Business Income as an Alternative to the Foreign Tax Credit Inbound Transactions: Business Taxation 6.1. Introduction 6.2. The Concept of "Engaged in a Trade or Business" 6.3. Income Effectively Connected with a U.S. Trade or Business 6.4. The Significance of Tax Treaties 6.5. The Treaty Concept of a "Permanent Establishment" 6.6. Earnings Stripping Non-Business Income-Inbound and Outbound Transactions 7.1. Introduction 7.2. Fixed, Determinable, Annual, or Periodical (FDAP) Income: Inbound Transactions 7.3. Non-Business Income: Outbound Transactions 7.4. Proposals for Integrating Taxes Internationally Portfolio Income-Enforcement and Administration 8.1. Challenges Confronting the Taxation of Foreign Portfolio Income 8.2. Evolution of the United States' Approach to Taxing Foreign Portfolio Income 8.3. Strategies for Monitoring International Portfolio Income 8.4. the Potential and Limits of Multilateral Solutions Transfer Pricing and the Allocation of Income among Related Parties 9.1. Introduction 9.2. The questionable premise of an arm's-length standard 9.3. History of Transfer Pricing Legislation in the United States 9.4. The Arm's Length Standard 9.5. Other Allocation Methods 9.6. Enforcement 9.7. Advanced Pricing Agreements The Nondiscrimination Principle 10.1. Introduction 10.2. The Scope of Nondiscrimination 10.3. Proffered Policy Rationales 10.4. Locational Neutrality 10.5. Nondiscrimination in the European Community 10.6. Rethinking the Goals of Nondiscrimination Tax Competition, Harmonization, and National Sovereignty 11.1. Approaching "Harmful Tax Competition" 11.2. Combating Evasion, Increasing Transparency 11.3. What is "Harmful" Tax Competition? 11.4. The Perspective of Developing Countries 11.5. Tax Harmonization As a "Solution" to Tax Competition 11.6. Multilateral Institutions As a "Solution" to Tax Competition
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