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Foreign Authors, Inventors, and the Income Tax, 72 Yale L.J. 1095 (1963)


FEW provisions in the Internal Revenue Code are the object of more polemics and pulpiteering than those governing taxation of foreign income. Yet the profusion of studies, tracts, books and bills on foreign taxation seldom actually concern foreign taxpayers "-,except to the extent that an American owned corporation is a "foreign" taxpayer because it has a foreign charter, does business abroad, and is taxed as a "foreign corporation" under the Code. The "legitimate" foreign corporation gets only peripheral attention in current dialogues; the nonresident alien is virtually ignored. Recent experience with balance of payments deficits and a lagging growth rate, however, emphasizes the importance of the foreigner in our economy-apart from his traditional role as customer. The United States no longer has a monopoly on exportable wealth, science, or mass media artistic products. The United States can use more investment from abroad and will increasingly need the art and technology of other countries as they continue to advance.

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