The main purpose here is an inquiry into the applicability of tax conventions, especially in the context of the personal scope. In other words, to whom are tax conventions applicable? That question means the first step of the application of tax conventions.In general tax conventions (treaties)...

In the United States and elsewhere, basic principles of international taxation have, in recent years, become the subject of vigorous debate and controversy. Historically, the United States has taxed residents, including domestic corporations, on worldwide income, but has allowed them credit for...