such as the surrogatum principle or the test in Gaynor v.
courts make this move as part of applying the surrogatum principle in
approach is to follow the surrogatum principle and that the foreign
law, will show that the indiscriminate application of the surrogatum
The majority essentially applied the surrogatum principle to hold that
This conclusion accords with the application of both the surrogatum
expenses and fully taxable income, and the surrogatum principle would
reasoning in Gaynor relies on the surrogatum principle to hold that the
paints the clearest picture of the contrast between the surrogatum
surrogatum principle is applied wholesale without consideration for the
Therefore, a correct application of the surrogatum principle would treat
simple application of the surrogatum principle may lead to inefficient