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Gift
The Arthur W. Diamond Law Library
Gift of Prof. Michael J. Graetz
Table of Contents
Foreword
Introduction
pt. 1. History ; The "original intent" of U.S. international taxation ; Historical perspective on Subpart F
pt. 2. Business income ; Taxing international income: inadequate principles, outdated concepts, and unsatisfactory policies ; Technological innovation, international competition, and the challenges of international income taxation ; A multilateral solution for the income tax treatment of interest expenses ; Structuring an exemption system for foreign income of U.S. corporations ; Can a 20th century business income tax regime serve a 21st century economy
pt. 3. Portfolio income ; Taxing international portfolio income
pt. 4. Europe ; Income tax discrimination and the political and economic integration of Europe
Acknowledgements
Notes
Index.
Introduction
pt. 1. History ; The "original intent" of U.S. international taxation ; Historical perspective on Subpart F
pt. 2. Business income ; Taxing international income: inadequate principles, outdated concepts, and unsatisfactory policies ; Technological innovation, international competition, and the challenges of international income taxation ; A multilateral solution for the income tax treatment of interest expenses ; Structuring an exemption system for foreign income of U.S. corporations ; Can a 20th century business income tax regime serve a 21st century economy
pt. 3. Portfolio income ; Taxing international portfolio income
pt. 4. Europe ; Income tax discrimination and the political and economic integration of Europe
Acknowledgements
Notes
Index.