1. Please distinguish between tax evasion and tax avoidance. Does managing cash flows, the type of business entity used, and personnel policy constitute tax evasion? Why do you say so?
2. How does the detail of business income taxation enter into the NPV analysis of international real investment?
3. What are the three degrees of presence in a foreign country? Please give the advantages and disadvantages of each.
4. With respect to business income, is the U.S. a worldwide taxing jurisdiction? Why do you say so? How do the BEAT provisions of the TJCA tend to preserve the taxability at U.S. rates of corporation income at U.S. rates?
5. What is a tax treaty?