Globalizing the tax function of the 21st century: have we met the challenges of the 20th century?

Article Abstract:

The future of international tax practices is the focus of this article in which the author offers insights into international business tax issues which may arise in the 21st century.

Forecasts and trends, Tax consultants

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Calculating earnings and profits under Code section 964

Article Abstract:

The author provides a detailed description of the calculation of earnings and profits of foreign corporations which, in years beginning in 1987, generally must follow the method in IRC section 964 as required by the Tax Reform Act of 1986.

Accounting Methods, Profit, Foreign corporations, Profits, Accounting

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What will "control: mean in international taxation in the next millennium?

Article Abstract:

The author discusses the meaning of the word "control" which is a determinative factor in the taxation of corporations with international affiliates. IRC section 482, which concerns income and deduction allocations, is the focus of the discussion.

Affiliated corporations, International business enterprises, Multinational corporations

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