The greatest conceptual difficulties of international taxation lie in questions

of characterization. These are even more acute tban in taxation

generally because of the greater opportunity in the international environment
to maneuver transactions into different tax regimes, some more
enjoyable than others. The real question in many cases ostensibly interpreting
a provision of law is "What happened" !uestions of
characterization are an undercurrent running through this boo", and
surface ubiquitously.