The Frame Game: How Defining the "Transaction" Decides the Case. (Reprinted from the Tax Lawyer, Vol. 63, P. 1, 2009) (Reprint)
Virginia Tax Review 2011, Fall, 31, 2
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Publisher Description
I. INTRODUCTION In this article, I make the following points:
Re-Thinking First Principles of Transfer Pricing Rules.
2011
Value in the Eye of the Beholder: The Valuation of Intangibles for Transfer Pricing Purposes.
2008
Too Big to Fail: The Problem of Partnership Allocations (Part 1)
2011
A Malthusian Analysis of the Socalled Dynasty Trust.
2009
From Gregory to Enron: The Too Perfect Theory and Tax Law.
2005
Take Me out to the Ball Game, But should the Crowd's Taxes Pay for It?
2010