38 Int'l Tax J. 1 (2012)

handle is hein.journals/intaxjo38 and id is 1 raw text is: Ii)~t~ ~L)

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Vol. 38, No. 1 January-February 2012
Contents
A NOTE FROM THE EDITOR-IN-CHIEF
Disputed Issues with the Application
of Code Sec. 367 to Intangibles
By Lowell D. Yoder
COLUMNS
Sovereign Wealth Funds
By Peter A. Glicklich and Meganj Grandinetti
France
By Bruno Gouthire
Ireland
By John Hickson

ARTICLES

Tax Consequences for Foreign Holders of Oil and Gas
Royalty Trust Units
By LindsayJ. Heyen and Victoria V Louie
The Impact of New Income Tax Law
on Foreign Invested Enterprises in China
By Suwina Cheng and Shanshan Shi
Unsettled Future for U.S. Taxpayers Residing Overseas:
Mixed Messages from IRS Commissioner vs. Ambassador-Part I       )
By Patrick W. Martin
An Update on General Anti-Tax Avoidance Rules in China
By Daniel K. C. Cheung

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