Part One
Index
- The Judicial Determination of Fair Market Value
- What to Expect from the Tax Court in a Lengthy Trial
- Effective Conduct of Commercial Litigation: A Judge's Perspective
- Tax Shelters, Technology, and the Future?- The Demise of the Software Tax Shelter and Lessons to be Learned for the Investor
- It's the Destination, Not the Journey: The Significance of the Tax Assessment Process in Tax Appeals
- Permanent Establishment and the Challenges of Electronic Commerce
- Bet on It: The Taxation of Online Gaming
- Tax Treaty Treatment of Royalty Payments from Low-Income Countries: A Comparison of Canada and Australia's Policies
- Tax Discrimination and the Trade in Services between Canada and the United States: Deciphering the Landscape
- R&D Credits: Reducing the Cost of Innovation
- Interpretative Issues Regarding SR&ED Tax Credits: An Overview of Recent SR&ED Tax Cases and Related Implications for Claimants
- Inbound Transfers of Technology
- Alternate Models for Acquiring Technology Products and Services
- Old Wine in New Wineskins'? Indirect Tax Challenges for International Transfers of Intangible Property
- Transfer Pricing the Technology
- The Evolution of the Use of Cost Sharing Arrangements in International Income Tax Planning and New Indications for Valuing Intellectual Property
- The U.S. International Taxation of the Transfer of Technology by American Enterprises: A Primer for the CFO, Tax Director, and Foreign Tax Advisor
- Going Global: Some Foreign Tax Fundamentals for the Expanding Technology Enterprise