international Tax law

in" rel="nofollow">international Tax law Order Description Question: Action 3 of the BEPS Action Plan seeks to develop recommendations for controlled foreign company (CFC) rules that are effective in" rel="nofollow">in dealin" rel="nofollow">ing with base erosion and profit shiftin" rel="nofollow">ing. Outlin" rel="nofollow">ine the role of CFC rules, explain" rel="nofollow">in what makes CFC rules an essential component of the BEPS Action Plan, and critically examin" rel="nofollow">ine the legal and policy considerations that need to be addressed when designin" rel="nofollow">ing CFC legislation. Your answer should be no more than 5,000 words (in" rel="nofollow">includin" rel="nofollow">ing footnotes but excludin" rel="nofollow">ing bibliography). Footnotes should be used only to supply references to sources. ASSESSMENT CRITERIA In assessin" rel="nofollow">ing coursework and dissertations, assessors will have regard to the followin" rel="nofollow">ing criteria: 1. RELEVANCE a. Identifies and focuses on the key issues and themes raised by the question b. Uses the relevant law to answer the specific question asked c. Does not refer to irrelevant material d. Avoids in" rel="nofollow">inaccuracies of fact and law. 2. UNDERSTANDING a. Shows a deep understandin" rel="nofollow">ing of relevant prin" rel="nofollow">inciples and key cases b. Uses appropriate examples to illustrate poin" rel="nofollow">ints and justify arguments c. Applies relevant authorities to the issues in" rel="nofollow">in a practical manner. 3. STRUCTURE and ORGANISATION a. Deals with relevant issues in" rel="nofollow">in a logical order b. Presents logical argument(s) c. Avoids repetition d. Shows good grammar and style e. Has appropriate physical layout. 4. ANALYSIS and EVALUATION a. Distin" rel="nofollow">inguishes between important and unimportant facts b. Explain" rel="nofollow">ins why a particular fact/issue/authority is important c. Does not simply take a fact/issue/authority at face value (lacks analysis) d. Does not simply state a fact/issue/authority (merely descriptive) e. Weighs up different positions and reaches conclusions. 5. USE and ATTRIBUTION of appropriate material a. Uses basic texts and module materials appropriately b. Cites sources appropriately and precisely c. Shows evidence of wider, in" rel="nofollow">independent, readin" rel="nofollow">ing, goin" rel="nofollow">ing beyond basic texts and module materials.