Courses

    Examines in detail the basic principles of international tax. The course is taught from a global perspective with the emphasis on comparative analysis. It is not intended to examine any one country's tax rules in detail, but rather to identify the core issues in developing international tax rules and study the different approaches countries have taken in dealing with these issues. Consideration is given to the tax rules in both developed and emerging economies. As part of the study, recent trends in the development of international tax rules will be identified and critiqued. Topics covered: jurisdiction to tax; development of residence rules; methods of international double tax relief; taxation of controlled foreign companies; development of source rules; methods of taxing non-residents; protecting the source country tax base (transfer pricing, thin capitalization and branch profits tax); basic operation of double tax treaties with particular emphasis on the OECD Model); and international issues in tax administration.