Contents
Preface
Acknowledgments
1 The Lohic of Tax
2 The Imprtance of Source
3 The Characterization of Income
4 The Allocation of Deductions
5 The Taxation of U.S.Nonbusiness Income
6 The Taxation of U.S.Business Income
7 Transferring Property Out of Residence Jurisdiction
8 Intercompany Pricing
9 Deferral and Its Exceptions
10 Avoiding Double Taxation:The United States Foreign Tax Credit
11 Terminating the Investment
12 A Brief(and Perhaps Temporary)Instruction in How to Undermine Almost Everything:Allocation of Interest Expense,Some Foreign Tax Credit Categories,and Subpart F
13 How to Read a Treaty
14 The End of the Lecture
Table of Cases
Index
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