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What is this Thing Called Source?

7 Pages Posted: 26 Mar 2011 Last revised: 5 Jun 2011

Lawrence Lokken

University of Florida College of Law

Date Written: March 25, 2011

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.

Suggested Citation

Lokken, Lawrence, What is this Thing Called Source? (March 25, 2011). University of Miami Legal Studies Research Paper No. 2011-12; University of Florida Levin College of Law Research Paper. Available at SSRN: https://ssrn.com/abstract=1795265 or http://dx.doi.org/10.2139/ssrn.1795265

Lawrence Lokken (Contact Author)

University of Florida College of Law ( email )

P.O. Box 117625
Gainesville, FL 32611-7625
United States

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