U.S. taxation of international income: blueprint for reform

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Corporate Taxation and Avoidance Economic and Fiscal Studies Taxation and Legal Issues

Abstract

This study of the basic structure of US taxation of international income (which has not changed substantially since the early 1950s) offers a groundplan for its reform in the economic realities of the 1990s. It deals with the implications for US international economic performance of ostensibly domestic tax policies, such as investment and research and development tax incentives. The book also examines the foreign tax credit approach versus the territorial approach to taxing foreign income; the arms-length approach versus the worldwide unitary approach to transfer pricing; and the use of foreign sales corporations and other means of stimulating US foreign exports.

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2003Tax Treaties, Renegotiations, and Foreign Direct Investment 2003Do Bilateral Tax Treaties Promote Foreign Direct Investment?1999Tax Holidays and Firms' Subsidiary Location Decisions 1996Free Trade Taxation and Protectionist Taxation 1994Free trade taxation and protectionist taxation 1999The Case against Deferral: A Deferential Reconsideration 2007US Taxation of Foreign Income 2009Reconsidering the Taxation of Foreign Income

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