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64 Tax Executive 1 (2012)

handle is hein.journals/taxexe64 and id is 1 raw text is: Chapter News ..................... 10 THE TAX EXECUTIVE The Professional Journal of Tax Executives Institute, Inc. Ever In , n'oWes soer of his tine to the upbilding of the profession lo which he belongs. - Theodore Roosevelf New Stories 27 Cloud Computing: U.S. Tax Compliance Complexity for Foreign Subsidiaries By James Carr, Jason Hoerner, Shirish Rajurkar, and Chanin Changtor 41 Insolvent Foreign Subsidiaries By Jasper L, Cummings, Jr. 57 Elevating Tax Department Productivity with an Efficiency Dividend By Steve Cranford, Fernando Murias, and Mark Schutzman Technical Submissions 61 TEI Washington Liaison Meetings 71 Canadian Tax Court: Proposals for Better Caseload Management 75 OECD: Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention 87 TEI Policy Statement on Independent State Tax Tribunals 89 Establishment of Alabama Tax Appeals Commission 91 British Columbia Provincial Sales Tax - Improvements The Tax Executive (ISSN 0040-0025), USPS 615940; Profession- al Journal of Tax Executives Institute, is published bimonthly by Tax Executives Institute, Inc. Periodicals is postage paid in Washington D.C. President, David M. Penney, General Motors of Canada Limited * Senior Vice President, Carita R. Twinem, Spectrum Brands, Inc. * Secretary, Terilea J. Wielenga, Allergan, Inc. * Treasurer, Mark C. Silbiger, The Lubrizol Corporation. C 2012 Tax Executives Institute, Inc. All rights reserved. Subscriptions: $120 per year U.S. and Canada. Other countries $145 per year. Must be U.S. funds. Address: The Tax Executive, 1200 G Street, N.W., Suite 300, Washington, D.C. 20005- 3814, phone 202.638.5601. Single copies and back issues available from: William S. Hein & Co., Inc., 1285 Main Street, Buffalo, NY 14209, Phone: 800.828.7571, Fax: 716.883.8100. For advertising and publication information, contact The Tax Executive, 1200 C Street, N.W., Suite 300, Washington, D.C. 20005-3814, phone 202.638.5601. POSTMASTER: Send ad- dress changes to The Tax Executive (at the address above). The views expressed in The Tax Executive are those of the authors and advertisers and may not reflect the official policy of Tax Executives Institute or The Tax Executive. No endorse- ment of those views should be inferred. JANUARY-FEBRUARY 2012 1

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