Ⅰ．The Logic of Tax

Summary of ContentsContents

Preface

Acknowledgments

Ⅱ．The Importance of Source

Ⅲ．The Characterization of Income

Ⅳ．The Allocation of Deductions

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(and Perhaps Temporary)Instruction in How to Undermine Almost Everything:Allocation 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