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38 Int'l Tax J. 1 (2012)

handle is hein.journals/intaxjo38 and id is 1 raw text is: Ii)~t~ ~L) SUSTAINABLE Certified Sourcing FORESTRY INITIATIVE w .sfiprogram.org SFI-00453 CCH Journals and Newsletters Emai Alert for the Current Issue Sign Up Here... CCHGroup.com/Email/Journals 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