Contents
Preface
Acknowledgments
I.The Logic of Tax
II.The Importance of Source
III.The Characterixation of Income
IV.The Allocation of Ddeuctions
V.The Taxation of U.S.Nonbusiness Income
VI.The Taxation of U.S.Business Income
VII.Transferring Property Out of Residence Jurisdiction
VIII.Intercompany Pricing
IX.Deferral and Its Exceptions
X.Avoiding Double Taxation:The United States Foreign Tax Credit
XI.Terminating the Investment
XII.A Brief Instruction in How to Undermine Almost Everything:Tllocation of Interest Expense,Some Foreign Tax Credit Categories,and Subpart F
XIII.How to Read a Treaty
XIV.The End of the Lecture
Table of Cases
Index