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Advanced Introduction to International Tax Law
Reuven S. Avi-Yonah
Advanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax.
DOI:
dx.doi.org/10.4337/9781781952320
HB: 9781781952313
PB: 9781781952375
EISBN: 9781781952320
Advanced Introductions
Published in print:
27 Feb 2015
Table of contents
Table of contents
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Front Matter
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Cover
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Half Title
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Title Page
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Copyright
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Contents
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Acknowledgements
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Abbreviations
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PART I OVERVIEW OF THE INTERNATIONAL TAX REGIME
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1 Introduction: the international tax regime
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2 Jurisdiction to tax and definitions
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2.1 Jurisdiction to tax
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2.2 Defining residence
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3 The source rules
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3.1 Formal source rules
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3.2 Substantive source rules
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3.3 The problem of sourcing
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3.4 Sourcing deductions
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4 Inbound taxation: passive income
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4.1 The general rule
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4.2 The exceptions in general
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4.3 The problem of distinguishing residents from non-residents
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5 Inbound taxation: active income
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5.1 Defining a TB or PE
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5.2 Attribution of income
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5.3 Special rules
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6 Transfer pricing
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6.1 The transfer pricing problem
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6.2 The classical methods and their limitations
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6.3 The profit-based methods
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6.4 The future of transfer pricing
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7 Outbound taxation: passive income
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7.1 FIF rules
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7.2 CFC rules
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8 Outbound taxation: active income
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8.1 The three hoops
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8.2 The foreign tax credit limit
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8.3 The indirect credit
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9 The tax treaty network
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9.1 The definitional articles
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9.2 The substantive articles
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9.3 The procedural articles
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9.4 Exchange of information
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PART II SELECTED CONTEMPORARY ISSUES
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10 Capital versus labor mobility
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10.1 Can capital avoid US taxation by moving?
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10.2 How immobile is labor?
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10.3 Policy implications
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11 The single tax principle
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11.1 The historical origins of the single tax principle
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11.2 Conclusion
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12 The problem of non-discrimination
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13 The future of transfer pricing
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13.1 The problems of the ALS
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13.2 The problems of formulary apportionment
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13.3 Adopting formulas in the context of the ALS
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13.4 Conclusion
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14 Base erosion and profit shifting
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14.1 Introduction
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14.2 Why tax multinationals?
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14.3 Taxing multinationals on global profits: a multilateral approach
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14.4 Response to common critiques
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14.5 Implications for developing countries
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14.6 Can the proposal be adopted?
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Appendix: can corporate tax rates be coordinated?
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15 Conclusion: the future of the international tax regime
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15.1 The problems
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15.2 A possible solution
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Back Matter
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Select bibliography
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Index
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Table of Contents
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