Transcription of INTERNATIONAL TAXATION: APPLICATION OF SOURCE …
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INTERNATIONAL TAXATION: APPLICATION OF SOURCE …
COPYRIGHT 2005 HOUSTON BUSINESS AND TAX LAW JOURNAL. ALL RIGHTS RESERVED. 205 INTERNATIONAL taxation : APPLICATION OF SOURCE RULES TO INCOME FROM INTANGIBLE PROPERTY Erin. L. Guruli* I. II. CURRENT TAXING III. CHARACTERIZATION OF TRANSACTIONS AND APPLICATION OF SOURCE RULES TO INCOME FROM INTANGIBLE A. B. Sales for Fixed or Contingent C. Manufacture and Sale of Goods Using Intellectual D. E. Space and Ocean IV. EXAMINATION OF PROPOSED V. I. INTRODUCTION Income derived from the use of intangible property1 has significantly increased over time with the evolution of technology and the growing number of commercial transactions between multinational enterprises. Use of intellectual property spans the continuum of income-generating activities, ranging from technical, scientific research to the creative expression of artistic * Ms.
COPYRIGHT © 2005 HOUSTON BUSINESS AND TAX LAW JOURNAL. ALL RIGHTS RESERVED. 208 HOUSTON BUSINESS AND TAX LAW JOURNAL [Vol. V in the Tax Reform Act of 198619 that ...
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