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International Tax Issues 2012 (Chicago)
Lowell D. Yoder
International Law, Tax
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Table of Contents
Table of Contents
Chapter 1. Tax Reform Approaches a Decision Point
Chapter 2. The U.S. International Tax System at a Crossroads
Chapter 3. Section 956: Investment in U.S. Property
Chapter 4. The Devil is in the Details: Problems, Solutions and Policy Recommendations with Respect to Currency Translation, Transactions and Hedging
Chapter 5. Code Sec. 988 and the Nonrecognition Provisions—Part I: Transfers of Foreign Currency Loans Receivable
Chapter 6. Code Sec. 988 and the Nonrecognition Provisions—Part II: Assumptions of Foreign Currency Denominated Liabilities
Chapter 7. Inherently Hedgeable: Hedging Foreign Currency Exposure Arising from the Branch Operations of a CFC
Chapter 8. Source of Domestic Debt Issuer’s Ordinary Income Resulting from Net Negative Adjustments or Cancellation of Indebtedness
Chapter 9. Hedges of Foreign Currency Risk Associated with Debt Instruments Held as Capital Assets
Chapter 10. Can Code Sec. 267(f) Defer an Issuer’s Code Sec. 988 Loss on the Repayment of its Debt?
Chapter 11. U.S. Tax Consequences of International Acquisitions
Chapter 12. Subpart F Sales & Services Planning
Chapter 13. Foreign Tax Credit Developments
Chapter 14. Section 909 and the Temporary Section 909 Regulations: Impact on Foreign Tax Credit Utilization
Chapter 15. U.S. Transfer Pricing Rules and Intangible Property
Chapter 16. U.S. Transfer Pricing: Recent Administrative Developments
Chapter 17. The Final Cost Sharing Regulations Attempt to Tighten the Loose Screws
Chapter 18. The Transfer of Workforce in Place to a Foreign Corporation
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