INTERNATIONAL TAX PLANNING.

By Williom C. Gifford Jr. '63. Washington.D.C. Management, Inc. (A Division ofThe Bureau of National Affairs, Inc.), 1974.500 PP. $30.

Not every Dartmouth alumnus or alumna will be enthrilled by the subject of this book. An extreme degree of specialized interest, or perhaps fanaticism, is necessary to carry a reader through, for example, 139 pages on the federal tax aspects of inter-company pricing. But to the lawyers and accountants, whether fanatic or not, to whom section 482 of the Internal Revenue Code is the very stuff of life, this collection of legislative, administrative, and judicial materials is a feast indeed. And to the student of international tax planning who must face each year a bulkier and less comprehensible mass of laws, reaulations, rulings, and decisions, this book provides as clear a guide to a number of murky issues as is likely to be found anywhere.

The book is, indeed, aimed primarily at students, including Gifford's own students at the University of Virginia School of Law. This is not to say that it is in any sense too simple or superficial for the practitioner. But the practitoner who is seeking clear and concise guidelines may be frustrated with a set of materials that is designed more to expose the reader to problems and to help him think through solutions than to dictate to him answers to his questions. The materials dealing with inter-company pricing, for example (a subject in which the author has had a great deal of practical experience), begin with five court decisions illustrating the historical development of the principles involved, introduce the applicable Treasury regulations, provide six more court decisions illustrating pricing methods, introduce further regulations, a revenue ruling, and some ABA proposed Internal Revenue Code sections, turn to excerpts from the Renegotiation Act of 1951 and from a text on renegotiation, provide tables of industry statistics as a guide to normal profit percentages, turn to a court case dealing with cost justification, continue with two Revenue rulings and five Revenue procedures providing for relief from double taxation in an international context, and conclude with the reprinting of an article on procedural issues under section 482.

About half the book is devoted to export operations, and of this half inter-company pricing accounts for the greater part, and alternative forms of organization for export operations, including a detailed discussion of controlled foreign corporations, make up a substantial part. Another quarter of the book deals with manufacturing abroad, including setting up and transferring assets to and from a foreign subsidiary. The remaining quarter of the book is taken up with repatriation of earnings and joint ventures in less developed countries.

The book is truly distinctive as a legal text in its use of problem cases. Law schools have only slowly and grudgingly admitted the use of problem cases that are so familiar to students at graduate and undergraduate business schools. Six problem cases are built around the international activities of a hypothetical corporation, calling for answers to specific questions and practical tax planning on the part of students us- ing the text. A combination of the best features of a business and legal education is, after all, what one would expect from a former student of this reviewer.

Mr. Williamson, who earned a law degree aswell as master's and doctoral degrees in businessadministration from Harvard, is Professor ofBusiness Administration at the Tuck School.