《TAXATION OF FOREIGN INCOME》求取 ⇩

PART ONE Taxation of Foreign Income in Countries Outside the United States1

OPENING COMMENTSRoy A.Wentz, Jr., Chief Counsel, Federal and Foreign Tax Divi- sion, E.I.du Pont de NemoursCompany Eugene J.Patton, Peat, Marwick, Mitchell Co1

Ⅰ.TAXATION OF FOREIGN INCOME AND FOREIGN BUSINESS IN EUROPER.Palmer Baker, Jr., Lord, Day Lord3

Ⅱ.TAXATION OF FOREIGN INCOME IN CANADAJ.Gear McEntyre, Deputy Minister of National Revenue-Taxation30

Ⅲ.TAXATION IN JAPAN: FOREIGN-SOURCE INCOME OF JAPANESE CORPORA- TIONS AND TAXATION OF INCOME OF FOREIGN CORPORATIONS DOING BUSINESS IN JAPANWilliam E.Pardoe, Law Department, Union Carbide Corporation40

Ⅳ.THE INTERNATIONAL TAX LAW OF MEXICOHenry J.Gumpel, Price Waterhouse Co.57

Ⅴ.TAX POLICIES OF LESS DEVELOPED COUNTRIES WITH RESPECT TO FOR- EIGN INCOME AND INCOME OF FOREIGNERSOliver Oldman, Professor of Law and Director, International Tax Program, Harvard Law School74

Ⅵ.How POLICIES OF FOREIGN COUNTRIES AFFECT THE UNITED STATES IN NEGOTIATING TAXTREATIESDavid R.Tillinghast, Hughes, Hubbard, Blair Reed89

Ⅶ.DISCUSSION OF TAXATION OF FOREIGN INCOME IN COUNTRIES OUTSIDE THE UNITED STATESEdward Dudley Callahan, Tax Counsel, Ford Motor Company W.R.Young, General Tax Counsel, Texaco Inc.104

PART TWOUnited States Taxation of Foreign-Source Income115

OPENING COMMENTS115

Ⅷ.PROBLEMS INVOLVED UNDER SECTION 367Robert J.McDonald, SullivanCromwell117

Ⅸ.EARNINGS AND PROFITS IN FOREIGN OPERATIONSLeslie Mills, Price Waterhouse Co.135

Ⅹ.SOME THOUGHTS ON SECTION 482Chester C.Hilinski, Dechert, Price Rhoads147

Ⅺ.COMPLIANCE PROBLEMS IN TAXATION OF INTERNATIONAL OPERATIONSDonald W.Bacon, Assistant Commissioner （Compliance）, Internal Revenue Service160

Ⅻ.COMPLIANCE PROBLEMS WITH EMPHASIS OF OFFICE OF INTERNATIONAL OPERATIONS COVERAGECharles W.Stewart, President, Machinery and Allied Products Institute175

ⅩⅢ.INTERNATIONAL TAX CONCEPTSLeon O.Stock, Peat, Marwick, Mitchell Co.189

ⅩⅣ.DISCUSSION OF UNITED STATES TAXATION OF FOREIGN-SOURCE INCOME212

PART THREE United States Policy and Objectives225

OPENING COMMENTS225

C.Lowell Harriss, Professor of Economics, Columbia University XVBACKGROUND OF GENERAL POLICYRaphael Sherfy, Turney, Major, MarkhamSherfy227

ⅩⅥ.TAXATION OF FOREIGN BUSINESS INCOME—THE CHANGING OBJECTIVESDan Throop Smith, Professor of Finance, Harvard Graduate School of Business Administration241

ⅩⅦ.THE UNITED STATES TAX SYSTEM AND INTERNATIONAL TAX RELATION- SHIPS—CURRENT DEVELOPMENTS, 1965-1966Stanley S.Surrey, Assistant Secretary of the Treasury256

BIBLIOGRAPHY303

INDEX333