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