Chapters in this book

1. Frontmatter i
2. Contents v
3. Preface xiii
4. PART I: Designing Tax Rules for Foreign Direct Investment
5. 1. Introduction: The Last Battleground of Globalization 3
6. 2. Taxing Foreign Direct Investment in a Non-cooperative Setting: Contributions by Alex Easson 18
7. 3. China’s Tax Incentive Regime for Foreign Direct Investment: An Eassonian Analysis 35
8. 4. Outbound Direct Investment and the Sourcing of Interest Expense for Deductibility Purposes 60
9. 5. Assessing the Foreign Direct Investment Response to Tax Reform and Tax Planning 84
10. PART II: The Impact of Globalization
11. 6. Improving Inter-nation Equity through Territorial Taxation and Tax Sparing 117
12. 7. Harmonizing Corporate Income Taxes in the United States and the European Union: Legislative, Judicial, Soft-Law, and Cooperative Approaches 138
13. 8. Missing Women: Gender-Impact Analysis and International Taxation 153
14. 9. Globalization and the Hong Kong Revenue Regime 171
15. PART III: Tax Treaties
16. 10. Canada’s Evolving Tax Treaty Policy toward Low-Income Countries 189
17. 11. Tax Treaties and the Taxation of Non-residents’ Capital Gains 212
18. 12. Tax Treaty Templates 239
19. PART IV: Taxing Cross-border Services and Service Providers
20. 13. Tax Discrimination and Trade in Services: Should the Non-discrimination Article in the OECD Model Treaty Provide the Missing Link between Tax and Trade Agreements? 257
21. 14. The New Services Permanent Establishment Rule in the Canada- United States Tax Treaty 280
22. 15. Consumption Taxation of Crossborder Trade in Services in an Age of Globalization 305
23. Contributors 329
24. Index 331