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Analysis of the basic structural elements of the foreign tax credit, indicating the theoretical concepts upon which the structure is built, and then appyling the knowledge of that structure to a consideration of the technical and often quite intricate details of implementation. The possible advantages and disadvantages of the foreign tax credit system are discussed.
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Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.