Taxing Offshore Investment Income

The authors, an international panel of experts, address the design and operation of offshore investment fund regimes. They explore questions such as: what interests do they cover? How do regimes calculate, or estimate, residents' shares of income? What credit is there for foreign tax? When do regimes allow residents to set off losses on their foreign investments against domestic income? How is the bite of regimes limited to save costs of compliance and administration or to relieve tax burdens on internationally mobile executives? This book is comparative, dealing with topics issue-by-issue rather than country-by-country. It is written for practitioners who need to understand how foreign investment fund regimes work, for scholars and students of international tax law and principles, and for policy makers tasked with designing foreign investment fund regimes for their countries.