Items
Details
Table of Contents
Introduction and overview
Source of income
Residence
The foreign tax credit
Deferral and controlled foreign corporation
Inbound transactions : business taxation
Non-business income : inbound and outbound transactions
Portfolio income : enforcement and administration
Transfer pricing and the allocation of income among related parties
The nondiscrimination principle
Tax competition, harmonization and national sovereignty.
Source of income
Residence
The foreign tax credit
Deferral and controlled foreign corporation
Inbound transactions : business taxation
Non-business income : inbound and outbound transactions
Portfolio income : enforcement and administration
Transfer pricing and the allocation of income among related parties
The nondiscrimination principle
Tax competition, harmonization and national sovereignty.