This article examines the U.S. tax consequences of the use of derivative instruments in international financing transactions. The outline focuses in large part on the inconsistent U.S. tax treatment that results &om the use of various derivative financial instruments in cross-border financing transactions and the resulting implications for U.S. withholding taxes on ordinary equity and debt investments.
Avi-Yonah, Reuven S. "The International Implications of Tax Reform." Tax Notes 69 (1995): 913. (Work published when author not on Michigan Law faculty.)