Tax Management International Journal |
Title | Subject | Authors |
Comments on Final and Proposed Foreign Base Company Shipping Regulations. | Law | Klein, K. |
Comments on New Proposed Regulations Under Section 897. | Law | Estes, C. |
Comments on Proposed Amendments to Section 367. | Law | Terr, L.B. |
Constructive Dividends to U.S. Parent in Non-Arm's Length Transactions: Rollover of Short Term Obligations as Investment in U.S. Property-Technical Advice on Memorandum. | Law | Dolan, K. |
Cross-Border Equipment Leasing into Canada. | Law | Ducharme, S. |
Current U.S. International Tax Scene. | Law | Khokhar, J.A. |
Current U.S. International Tax Scene - Practitioner's Viewpoint. | Law | |
Definition of a Resident Alien - Proposed Legislative Changes. | Law | Zagaris, B. |
Final Capital Gains Rules for Foreign Tax Credit Computations. | Law | Green, W.H. |
Final Foreign Tax Credit Regulations Effect an Important Change in Separate Levy Rules. | Law | Cooper, M.T. |
Five Percent Tax Rate under U.S.-Netherlands Income Tax Treaty and the Impact of Anti-Abuse Provision. | Law | Fogarasi, A.P. |
Focus on the Canadian International Tax Scene - Current Developments. | Law | Boidman, N. |
Foreign Personal Holding Company Attribution Rules- Proposed Legislative Changes. | Law | Dale, H.R. |
International Aspects of the 1983 Social Security Amendments. | Law | Bissell, T.G. |
IRS Attack on Domestic Branching. | Law | Jerr, L.B. |
Loss Disallowed in Intercompany Sale Following Section 332 Liquidation. | Law | Melnick, R.J. |
Marine Construction Activities Held to Constitute Manufacturing within Regs 1.61(a)-Rev. Rul. 83-118. | Law | Estes, C. |
Proposed Legislation to Limit Tax Benefits Available for Property Leased to Foreign Persons. | Law | Foster, D.S. |
September 1983 Proposed Regulations Concerning Foreign Debt Registration Reguirements. | Law | Klein, K. |
Status-Changing Citizens Gross Income Includes a Simple Trust Income Prorated over Period of Citizenship. | Law | Dale, H.P. |
Status of U.S. Tax Treaties. | Law | Fogarasi, A., Venuti, J., Renfroe, D. |
The Income Tax Conventions Interpretation Act - A Lesson in Unilateral Treaty Amendment by Canada. | Law | McCart, J., Morris, B. |
The Jurisdiction of United States Courts to Order the Production of Documents Located Abroad in Section 482 Investigations: U.S. v. Toyota Motor Corp. | Law | McCawley, H.B. |
The Service Proposes New Regulations Under Section 897. | Law | Ruchelman, S. |
The Tax Court Ignores Sham and Section 367 Arguments but Utilities 482 to Allocate Income - Hospital Corp. of America v. Comr. | Law | Solomon, M. |
Trends: Belgium. | Law | Lebrun, P.F. |
Trends: Switzerland. | Law | Stucki, H.V., Altenburger, P.R. |
Trends: United Kingdom. | Law | Young, D.T. |
U.S. Adopts Restrictive Interpretation of Nondiscrimination Article of the Philippines Treaty. | Law | Foster, D.S. |
U.S.-Denmark Protocol Exemplifies U.S. Efforts to Prevent Imposition of Balancing Charge on U.S. Drilling Contractors. | Law | Cooper, M.J. |
Washington Items. | Law | |
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