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Summary

CHAPTER 1 : The judicial Determination of Fair Market Value @ Page 3 CHAPTER 2 : What to Expert from the Tax Court in a Court in a Legthy Trial @ Page 23 CHAPTER 3 : Effective Conduct of Commercial Litigation : A judge's Perspectives @ Page 41 CHAPTER 4 : Tax Shelters , Technology, and the Future? The Demise of the Software Tax Shelter and Lessons to be Learned for the Investor @ Page 55 CHAPTER 5 : It's the Destination , Not the journey : The Significance of the Tax Assessment Process in Tax Appeals @ Page 81 CHAPTER 6 : Permanent Establishment and the challenges of Electronic Commerce @ Page 99 CHAPTER 7 : Bet on it : The Taxation of Online Gaming @ Page 115 CHAPTER 8 : Tax Treaty Treatment of Royalty Payments from low - Income Countries : A Comparison of Canada and Australia 's Pollicies @ Page 139 CHAPTER 9 : Tax Discrimination and the Trade in Services between Canada and the United States: Deciphering the Landscape @ Page 179 CHAPTER 10 : R&D Credits : Reducing the Cost of Innovation @ Page 225 CHAPTER 11 : Interpretative Issues Regarding SR&ED Tax Credits : An Overview of Recent SR&ED Tax Cases and Related Implications for Claimants @ Page 245 CHAPTER 12 : Inbound Transfers of Technology @ Page 277 CHAPTER 13 : Alternate Models for Acquiring Technology Products and services @ Page 319 CHAPTER 14 : "Old Wine in New Wineskins'? Indirect Tax Challenges for International Transfers of Intangiable Property @ Page 341 CHAPTER 15 : Transfer Pricing the Technology @ Page 373 CHAPTER 16 : The Evolution of the Use of Cost Sharing Arrangements in International Income Tax Planning and New Indications for Valuating Intellectual Property @ Page 401 CHAPTER 17 : The U.S International Taxation of theTransfer of Technology by American Enterprises : A Primer for the CFO, Tax Director , and Foreign Tax Advisor @ Page 423 CHAPTER 18 : Going Global : Some Foreign Tax Fundamentals for the Expanding Technology Enterprises @ Page 457 CHAPTER 19 : Valuation Methologies : The Current Art and Science @ Page 473 CHAPTER 20 : The Invisible Path : Valuing Technology @ Page 533 CHAPTER 21 : Valuation of Biotechnology Companies and their Assets @ Page 577 CHAPTER 22 : Transfer and Valuation of Biomedical Intellectual Property @ Page 603 CHAPTER 23 : Protected Assets : Valuing Patents @ Page 643 CHAPTER 24 : Discounts and Premiums : Artistics Licence and Science @ Page 667 CHAPTER 25 : Valuing Business in the Ever -changing Global Marketplace @ Page 687 CHAPTER 26 : Tips from the Field @ Page 719 CHAPTER 27 : Technology Valuations and the Canada Revenue Agency @ Page 749 CHAPTER 28 : The Investor's Approach to Valuation of Early - Stage Technology Companies @ Page 777 CHAPTER 29 : Tips from the Top @ Page 801 CHAPTER 30 : Intellectual property and Damage Quantification @ Page 847 CHAPTER 31 : Growth by design : How Good Design Dric-ves Value @ Page 883 CHAPTER 32 : Technology Transfer: An Overview with a Government Research Perspective, or Sometimes it is a Platypus not a Duck! @ Page 963