International tax law covers the rules on taxation in cross-border situations. National tax law reaches out to bases of taxation located abroad, if nationals or persons domiciled within the country earn income or hold assets in foreign territory. A State’s tax jurisdiction also extends to foreign persons who earn income or hold property within the State. Customary international law requires a personal or territorial link for the exercising of jurisdiction to tax. The Restatement (Third) of the US Foreign Relations Law1 provides in § 412: The ‘world income...
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