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Ⅰ．The Logic of Tax 1

Summary of ContentsContents 13

Preface 29

Acknowledgments 33

Ⅱ．The Importance of Source 39

Ⅲ．The Characterization of Income 101

Ⅳ．The Allocation of Deductions 199

Ⅴ．The Taxation of U.S. Nonbusiness Income 223

Ⅵ．The Taxation of U.S.Business Income 241

Ⅶ．Transferring Property Out of Residence Jurisdiction 339

Ⅷ．Intercompany Pricing 395

Ⅸ．Deferral and Its Exceptions 451

Ⅹ．Avoiding Double Taxation:The United States Foreign Tax Credit 533

Ⅺ．Terminating the Investment 669

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 685

ⅩⅢ．How to Read a Treaty 693

ⅩⅣ．The End of the Lecture 721

Table of Cases 727

Index 731