Now showing items 21-25 of 25

    • Treasury Can Close a Potential Loophole in the Treatment of Deferred Foreign Income in the Tax Cuts and Jobs Act – Will It Act? 

      Shay, Stephen E. (2017)
      This paper points out a potential TJCA loophole allowing a reduction in aggregate foreign cash subject to the 15.5% rate unless Treasury takes steps to implement an anti-abuse rule. If Treasury does not act, aggressive ...
    • Treasury’s Unfinished Work On Corporate Expatriations 

      Shay, Stephen E.; Fleming, J. Clifton, Jr.; Peroni, Robert J. (Tax Analysts, 2016)
      Continued tax-motivated inversions of U.S. corporations into foreign corporations highlight the systemic tax advantages that a foreign-owned U.S. corporation has over a U.S.-owned corporation in avoiding U.S. corporate tax ...
    • The Truthiness of ‘Lockout’: A Review of What We Know 

      Shay, Stephen E. (Tax Analysts and Advocates, 2015)
      Shay reviews what is known about ‘‘lockout’’ and unrepatriated offshore earnings. He concludes that the limited evidence available does not support claims that economic harm from lockout justifies shifting to a territorial ...
    • Two Cheers for the Foreign Tax Credit, Even in the BEPS Era 

      Fleming, Jr., J. Clifton; Peroni, Robert J.; Shay, Stephen E. (2016)
      Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons ...
    • Worse than Exemption 

      Shay, Stephen E.; Flemming Jr., J. Clifton; Peroni, Robert J. (Emory Law Journal, 2009)
      In this article, we discuss how various defects in the current U.S. international tax system - deferral, defective income-sourcing and cost allocation rules, lenient transfer-pricing rules, generous cross-crediting, the ...