International Taxation Discussion

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General Instructions:

You are entitled to utilize class materials, class notes, outlines, and relevant commercial law statutes.

If there are facts you need, which are not provided in the essay questions, state them and indicate the differing results which might ensue from different factual assumptions. For United States individuals, assume that the tax rate is 35 percent; for domestic corporations 21 percent. For non-United States persons, with respect to any business and investment income subject to tax by the United States, assume that it is taxed at the highest statutory rate of 35 percent for individuals and 21 percent for corporations (active) and 30 percent (passive) unless governed by treaty, in which case the relevant treaty rate will control. Chile has not entered a tax treaty with the United States, while Canada has. In all foreign jurisdictions, unless otherwise specified, assume that business income is taxed at 40 percent and investment income at 20 percent unless governed by treaty, in which case the relevant treaty rate will control.

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