Globalization and its tax discontents : tax policy and international investments : essays in honour of Alex Easson

Innovative, interdisciplinary, and comprehensive, __Globalization and Its Tax Discontents__ sheds light on one of the last real policy battlegrounds of globalization. Contents 5 Preface 13 PART I: Designing Tax Rules for Foreign Direct Investment 17 1. Introduction: The Last Battleground of Globalization 17 2. Taxing Foreign Direct Investment in a Non-cooperative Setting: Contributions by Alex Easson 32 3. China’s Tax Incentive Regime for Foreign Direct Investment: An Eassonian Analysis 49 4. Outbound Direct Investment and the Sourcing of Interest Expense for Deductibility Purposes 74 5. Assessing the Foreign Direct Investment Response to Tax Reform and Tax Planning 98 PART II: The Impact of Globalization 131 6. Improving Inter-nation Equity through Territorial Taxation and Tax Sparing 131 7. Harmonizing Corporate Income Taxes in the United States and the European Union: Legislative, Judicial, Soft-Law, and Cooperative Approaches 152 8. Missing Women: Gender-Impact Analysis and International Taxation 167 9. Globalization and the Hong Kong Revenue Regime 185 PART III: Tax Treaties 203 10. Canada’s Evolving Tax Treaty Policy toward Low-Income Countries 203 11. Tax Treaties and the Taxation of Non-residents’ Capital Gains 226 12. Tax Treaty Templates 253 PART IV: Taxing Cross-border Services and Service Providers 271 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? 271 14. The New Services Permanent Establishment Rule in the Canada- United States Tax Treaty 294 15. Consumption Taxation of Crossborder Trade in Services in an Age of Globalization 319 Contributors 343 Index 345

Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. Agreements such as NAFTA in North America and the regional integration of the European Union facilitate cross-border commerce. While trade has become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to the flow of cross-national investments.

In Globalization and Its Tax Discontents, some of the world's leading international tax scholars identify the ways that taxes can inhibit or promote international investments, and assess both government and private market responses to present challenges. Given the lack of meaningful government cooperation, the contributors integrate economic theory with elements of history, gender theory, and international relations to explore the potential development effective international tax rules and processes to tax international investments. Innovative, interdisciplinary, and comprehensive, Globalization and Its Tax Discontents sheds light on one of the last real policy battlegrounds of globalization.

Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. Agreements such as NAFTA in North America and the regional integration of the European Union facilitate cross-border commerce. While trade has become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to the flow of cross-national investments. In Globalization and Its Tax Discontents, some of the world's leading international tax scholars identify the ways that taxes can inhibit or promote international investments, and assess both government and private market responses to present challenges. Given the lack of meaningful government cooperation, the contributors integrate economic theory with elements of history, gender theory, and international relations to explore the potential development effective international tax rules and processes to tax international investments. Innovative, interdisciplinary, and comprehensive, Globalization and Its Tax Discontents sheds light on one of the last real policy battlegrounds of globalization "This book draws from essays given at a symposium held in honour of Professor [Alex] Easson at Queen's Law on 29 February 2008"--Preface