Search
Now showing items 1-10 of 30
Mr. Secretary, Take the Tax Juice Out of Corporate Expatriations
(Tax Analysts, 2014)
The lack of government response to the current wave of tax-motivated corporate expatriations is disheartening. Senate Finance Committee Chair Ron Wyden, D-Ore., Sen. Carl Levin, D-Mich., and Rep. Sander Levin, D-Mich., are ...
Worse than Exemption
(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 ...
Base Erosion and Profit Shifting: A Roadmap for Reform
(IBFD, 2014)
In this Editorial, the authors explain the context of this special issue of the Bulletin for International Taxation. The fundamental premise of the BEPS project is that a coordination of national responses to BEPS can both ...
Getting From Here to There: The Transition Tax Issue
(Tax Analysts, 2017)
If there is fundamental U.S. international income tax reform, regardless of the reform option chosen, the United States must decide how to handle the $2.4 trillion to $2.6 trillion of previously untaxed foreign income ...
Assessing BEPS: Origins, Standards, and Responses
(International Fiscal Association, 2017)
The G20/OECD’s multi-year campaign to combat base erosion and profit shifting (BEPS) marks a critical step in the evolution of the international tax regime and the roles of institutions that guide it. This General Report ...
The Truthiness of ‘Lockout’: A Review of What We Know
(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 ...
Designing a U.S. Exemption System For Foreign Income When the Treasury is Empty
(Tax Analysts, 2012)
The U.S. government faces a well-documented long-term revenue shortage that is unlikely to be cured by government expenditure reductions. Thus, it is curious that there is currently considerable pressure for the United ...
Designing a 21st Century Corporate Tax — An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base
(Tax Analysts, 2015)
The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This Article continues our exploration of second-best international tax reforms that would protect the U.S. corporate tax base ...
Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income
(Tax Analysts, 2001)
Although the ability-to-pay fairness principle is a foundational element of American income tax policy, it has played a surprisingly small role in evaluating the U.S. international income tax regime. Perhaps this is because ...
Lessons the United States Can Learn From Other Countries' Territorial Systems For Taxing Income of Multinational Corporations
(Urban Institute & Brookings Institution Tax Policy Center, 2015)
The United States has a worldwide system that taxes the dividends its resident multinational corporations receive from their foreign affiliates, while most other countries have territorial systems that exempt these dividends. ...