Type of Credit: Elective
Credit(s)
Number of Students
Since the 2008-2009 financial crisis, the complex planning of multinational enterprises in the area of tax has caught much attention of the societies around the world. In addition, the events surrounding Panama Papers and Paradise Papers have also caused many governments to attempt to address the enforcement issues for foreign related tax matters.
This course aims to examine the various ways in which various jurisdictions tax individual persons and legal persons on their activities both within and beyond their borders. This course introduces the basic structure of international tax law and its foundational concepts, and prepares students to do research on the contemporary topics, including the Base Erosion and Profit Shifting (BEPS) project, the 2017 Tax Cuts and Jobs Act (TCJA) of the United States, and the ongoing efforts by more than 130 jurisdictions to realize their two-pillar deal, including the so-called "global minimum tax," reached in October 2021.
能力項目說明
1. Learning the basic structure of international tax law and its foundational concepts.
2. Learning to do research on relevant topics.
3. Learning the various ways to evaluate the policy implications of law and court judgments.
| 教學週次Course Week | 彈性補充教學週次Flexible Supplemental Instruction Week | 彈性補充教學類別Flexible Supplemental Instruction Type |
|---|---|---|
If it becomes necessary to move some sessions to another date, it will be announced beforehand and made convenient for most students.
學期中如不得已需要調整部分課程時間，將提前宣布，並選擇多數同學便利的時間。
Class participation (課堂參與) will be graded in part by two one-page essays in response to class assignments and class discussion.
|
週次 |
課程主題 |
課程內容與指定閱讀 |
教學活動與作業 |
學習投入時數（課堂講授） |
學習投入時數（課程前後） |
|
1 |
|
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
2 |
Residence rules |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
3 |
Source rules |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
4 |
Threshold for taxing business income |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
5 |
Income Tax Treaties |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
6 |
Mid-term exam |
|
|
0 |
0 |
|
7 |
Controlled foreign corporations (CFC) and related rules |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
8 |
Tax treaties: Treaty shopping and the “limitation on benefits” clause |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
9 |
Investigations and the Exchange of information |
Slides prepared by the instructor |
Lecture and class discussion |
|
|
|
10 |
Tax treaties: Exchange of information |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
11 |
Transfer pricing: history and methods |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
12 |
Transfer pricing: documentation and dispute resolution |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
13 |
Thin capitalization rules |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
14 |
Transnational legal process |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
15 |
International tax policy |
Slides prepared by the instructor |
Lecture and class discussion |
3 |
3 |
|
16 |
Final Exam |
|
|
0 |
0 |
|
17 |
Self-Study |
Self-Study |
|
3 |
3 |
|
18 |
Self-Study |
Self-Study |
|
3 |
3 |
期中考(mid-term exam) 30%
期末考(final exam) 40%
課堂參與(class participation) 30%
Students should actively participate in class discussion.
期中考與期末考的題型為選擇題與簡答題，有參與課堂討論的同學均能輕鬆回答。Both mid-term exam and final exam consist primarily of multiple-choice questions and short essay questions. They are not difficult for students who participate in class sessions.
Class participation (課堂參與) will be graded in part by two one-page essays in response to class assignments and class discussion. The first essay will be due on October 13. The second essay will be due on November 24.
Materials assigned by the instructor.