Starting from these requirements of reciprocity and enforcement, Roy Rohatgi, an Arthur Andersen veteran with decades of experience, explains in this book the practical issues affecting international taxation of business income and capital gains. Unlike many books on this complex subject, his approach does not examine the tax perspective of any one country, but proceeds from an identification and analysis of the basic principles of the subject. This entails an understanding of factors, such as:
+ domestic tax laws, rules and practices and how they conflict on cross-border transactions;
+ bilateral tax treaties and their role in resolving international tax conflicts;
+ the use of offshore financial centres in international tax structures and how to choose them;
+ anti-avoidance measures imposed by national taxation authorities;
+ the application of national judicial decisions and interpretations of national authorities; and
+ international tax guidelines and interpretations of bodies such as the Organisation for Economic Cooperation and Development (OECD) and the International Fiscal Association (IFA).
Basic International Taxation describes each and all of these elements, weaving them into practical planning guidance providing a fundamental understanding of this subject in a single, easy-to-follow book. It explains those principles of international tax planning that take the costs and risks of international taxation fully into account and thereby optimize the after-tax returns on cross-border transactions. Several important current issues, including the taxation of electronic commerce, are also addressed.
Practitioners and students of tax law will benefit enormously from this clear-headed guidance, both for its day-to-day reference value and for the depth of understanding it conveys concerning essential principles.
