History, nature and concept of International Taxation, an overview of world-wide International Tax Systems - Economics of International Trade and Taxation. Basic Jurisdictional Tax Principles outbound transactions - inbound transactions - citizenship and residence. National activities of Foreign Tax Payers, the source rules, and enforcement through withholding Income Tax Treaty Provisions - None Discrimination Clause, Residence Clause, Permanent Establishment and Business Income, Investment Income, Earned Income. Relief from Double Taxation, Tax sparing.Tax planning and treaty shopping, Foreign Tax Credit, Inter-Company pricing controlled Foreign Corporations, Foreign Currency International ax- Free Transactions.Special Incentives.

 


Level of Study: 600 Level