April 5, 2011
Lokken: What is this Thing Called Source?Lawrence Lokken (Florida & Miami) has posted What is this Thing Called Source? on SSRN. Here is the abstract:
Although income source is fundamental to international tax system, the U.S. source rules are seemingly ad hoc and lack a general conception of the idea of income source. This brief paper is a preliminary attempt to develop a general concept of source.
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