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Chapter 1 Bases for International Tax£º 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¡ª¡ªfrom Special Tax Adjustments Rules I£® Other Anti-Deferral Measures J£® Questions for Further Consideration Chapter 9 Thin Capitalization and Rules A£® Thin Capitalization£º 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£º 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