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5 J. Tax'n Global Transactions 1 (2005-2006)

handle is hein.journals/jtxgt5 and id is 1 raw text is: & n 1[j11r Vol. 5, No. 1 Spring 2005 Contents COLUMNS Anti-Deferral and Anti-Tax Avoidance By Peter A. Glicklich and Pamela L. Marcogliese 5 Technology and Telecommunications By Richard E. Andesen 9 Transfer Pricing By James M. O'Brien and Mark A. Oates 13 Foreign Tax Credits By James A- Riedy 21 International Partnerships Joint Ventures and Hybrids By Edward C. OsterbergJr. 2 ARTICLES Global Sourcing Creates Tax Changes from Manufacturing to the Global Trade Model By Charles Goulding 27 Check-the-Box: Some Practical Issues in the International Area Cl By William H. Morris L Analyzing Cross-Border M&A Transactions After the Proposed Code Sec. 367 Regulations and the Jobs Act-Part I of II A By Steven M. Surdell and David A. Waimon 4t3 CONFERENCES 63

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