This article presents information regarding the symposium, conducted in the December 1965. This symposium was the outgrowth of substantial foreign investment and the complications of the 1962 amendments to the Internal Revenue Code regarding taxation of foreign income. It includes the treatment of foreign income by other countries as well as by the United States. Three broad categories of subject matter are covered, namely, taxation of foreign income in countries outside of the United States. United States taxation of foreign source income, and United States policy and objectives. Attention is directed in Part One to the taxation by various countries of foreign income of their own nationals as well as to the treatment accorded foreigners who derive income from such countries. The second major part of the symposium was devoted to United States taxation of foreign-source income, it included a discussion of Internal Revenue Code Section 367, Section 482, earnings and profits in foreign operations, compliance problems, and international tax concepts.
Griffin et al. (Sat,) studied this question.