International tax as international law : an analysis of the international tax regime / Reuven S. Avi-Yonah.

Format:

Book

Author/Creator:

Avi-Yonah, Reuven S. (Reuven Shlomo), 1957- author.

Series:

Cambridge tax law series

Language:

English

Subjects (All):

Income tax--Foreign income.

Income tax.

Business enterprises, Foreign--Taxation--Law and legislation.

Business enterprises, Foreign.

Noncitizens--Taxation--Law and legislation.

Noncitizens.

Double taxation.

Physical Description:

1 online resource (ix, 213 pages) : digital, PDF file(s).

Place of Publication:

Cambridge : Cambridge University Press, 2007.

System Details:

text file

PDF

Summary:

This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.

Contents:

Jurisdiction to tax

Sourcing income and deductions

Taxation of non-residents : investment income

Taxation of non-residents : business income

Transfer pricing

Taxation of residents : investment income

Taxation of residents : business income

The United States and the tax treaty network

Tax competition, tax arbitrage, and the future of the international tax regime.

Notes:

Title from publisher's bibliographic system (viewed on 05 Oct 2015).

Other Format:

Print version:

ISBN:

9780511511318

Access Restriction:

Restricted for use by site license.