国际税收（英文版）

Chapter 1 Bases for International Tax： Jurisdiction Taxation
A． Overview of Taxation in the United States
B． Overview of Taxation in the Republic of Ireland
C． Comparison Tables of Tax Features in Different Jurisdictions in the World
D． Questions for Further Consideration
Chapter 2 International Income Taxation
A． Income Tax
B． International Income Taxation
C． Questions for Further Consideration
Chapter 3 Tax Residence Issue
A． Significance of Residence for Tax Purposes
B． Outline of Definitions of Residence for Tax Purposes
C． Tax Residence in the United Kingdom
D． Tax Residence for Individuals in Germany
E． Comparison of Residence Standards for Particular Jurisdictions
F． China's SAT Issues Guidance on Tax Residence Status of Chinese
Controlled Offshore Companies
G． Certification of Resident Status in Arrangement between the
Mainland of China and the HKSAR for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion
H． Questions for Further Consideration
Chapter 4 Income Source Jurisdiction and Rules
A． General Theory
B． Income Source Rules in United States
C． Source Rules in China
D． Income Source Tests in Germany
E． Questions for Further Consideration
Chapter 5 International Double Taxation and Relief
A． General Theory
B． Relief from International Double Taxation
C． International Double Taxation Treaty or Agreement
D． Calcaulation Examples for Relief of International Double Taxation
Arising from Residence-Source Conflict． Simple Examples
E． Foreign Tax Credit in USA
F． Questions for Further Consideration
Chapter 6 International Tax Avoidance and Tax Haven
A． Tax Avoidance and Tax Evasion
B． International Tax Avoidance and Tax Haven
C． Tax Haven
D． Questions for Further Consideration
Chapter 7 International Transfer Pricing and Rules
A． Introduction to Concepts Definition
B． General Tax Principles of Transfer Pricing Rules
C． Specific Transfer Pricing Rules in the United States
D． Specific Tax Rules in OECD
E． Specific Tax Rules in China
F． Questions for Further Consideration
Chapter 8 Controlled Foreign Corporation and Rules
A． Why Need CFC Rules?
B． Basic Mechanisms
C． Subpart F Rules in United States
D． CFC Rules in United Kingdom
E． CFC Rules in Germany
F． CFC Regulations in Italy
G． CFC Rules in Japan and Other Countries
H． CFC Rules in China——from Special Tax Adjustments Rules
I． Other Anti-Deferral Measures
J． Questions for Further Consideration
Chapter 9 Thin Capitalization and Rules
A． Thin Capitalization： General Theories
B． Thin Capitalization Rules in China
C． Thin Capitalization Rules in United States
D． Brazil Introduces Thin Capitalisation Rules
E． Questions for Further Consideration
Chapter 10 International Tax Treaty
A． History of Two Model Tax Conventions
B． The UN Model Tax Convention as Compared with the OECD
Model Tax Convention-Current Points of Difference： Examples
C． Main Contents of a Typical Treaty
D． Tax Treaty Shopping & Anti-Tax Treaty Shopping
E． German Anti-Tax Treaty Shopping Rules
F． Questions for Further Consideration
Chapter 11 International Tax Competition and Harmonization
A． International Tax Competition
B． Tax Harmonization
C． Questions for Further Consideration
Chapter 12 International Taxation under Electronic Commerce
A． Global Trends of Electronic Commerce
B． Overview of Tax Issues
C． Direct Tax Issues Addressed by the OECD
D． Questions for Further Consideration
Selected References
Appendix A． English Edition for Agreement between the Government of the
People's Republic of China and the Government of Ireland for the Avoid-
ance of Double Taxation and the Prevention of Fiscal Evasion with respect
to Taxes on Income
Appendix B． Chinese Edition for Agreement between the Government of the
People's Republic of China and the Government of Ireland for the Avoid-
ance of Double Taxation and the Prevention of Fiscal Evasion with respect
to Taxes on Income
Appendix C． Taxation in the People's Republic of China
Appendix D． Sample Test Paper and Keys