Special issues such as the taxation of foreign and domestic entities subject to special tax regulations are addressed. Furthermore, this lecture covers mergers and taxation of groups, international taxation, taxation of foreign income to domestic recipients and taxation of domestic income to foreign recipients as well as procedural issues, procedure reporting and the exchange of information. This lecture deals with the national and international Dutch tax system by examining the general characteristics of its tax system, the taxation of profits, capital income and capital gains, fiscal consolidation, mergers and demergers, participation exemption, abuse of law, partnerships, ruling practice and tax treaty policy. However, there are also significant differences, not least within the field of tax law. The lecture provides a general overview of the Nordic tax systems by focusing on issues of special interest to persons from non-Nordic countries.
Attention is focused on three main areas.
First, issues of general theoretical interest such as the dual income tax. Second, essential rules particularly for foreign investors, and also to, for instance, Swedish companies investing abroad. Third, international tax issues which deal with the Nordic multilateral tax treaty together with main principles of domestic international tax law. Finally corporate tax issues will be highlighted. This lecture introduces and explains the tax law of the United States of America, with emphasis on the U.S. Federal Income Tax and the U.S. International Income Tax System.