| International Taxation |
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International tax is an extremely broad, challenging, important, and exciting field. The growing importance of international tax is matched by its difficulty. International tax rules are often the most technically difficult provisions of a country’s tax system. Rules such as thin capitalization rules, controlled foreign corporation rules, the indirect foreign tax credit, and rules for dealing with foreign exchange gains and losses are noted for their technical complexity. Managers and business owners working in the international area must not only understand the international tax rules of their own country, but must also have an understanding of the tax laws of the other countries involved in a transaction and any tax treaties between the countries. The challenge is exacerbated by the pace of change in the rules governing international tax. These changes include new treaties, amendments to countries’ international tax legislation and administrative practice, and new commercial developments such as new financial products and electronic commerce.
This course examines the basic principles surrounding international taxation. The course uses no textbook. All the reading materials necessary for an understanding of the course and its objectives are provided – including the judicial decisions which will be examined.
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