Foundations of international income taxation

Abstract

Because of the importance of technological innovation to economic growth, nations strive to stimulate and attract the research and devel opment ("R&D") that leads to that innovation and to make themselves hospitable environments for the holding of intellectual property ("IP"). Tax policies have taken center stage in their efforts to accomplish these goals and to capture a share of the income from technological innova tions. Designing cost-effective methods of supporting technological inno vations has, however, become substantially more difficult as the world economy has become more interconnected. Where R&D is performed and where income is earned change in response to the nature and level of government support. The capacity of multinational enterprises CMNEs") to shift their IP production, IP ownership, and IP income across national borders, along with their ability to establish new corpora tions in tax-favorable jurisdictions, makes designing cost-effective incen

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