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Since 1992, new issues have arisen in international taxation—for example, taxation of electronic commerce, novel means of shielding passive income, the World Trade Organization (WTO) debate over the foreign sales corporation and subsequent passage of the American Jobs Creation Act of 2004, the problem of corporate inversions, and alleged "earnings stripping" by foreign-based multinational enterprises (MNEs) operating in the United States. In the meantime, US-based MNEs operating abroad have used a variety of methods to cut the effective US tax on repatriated foreign source income to around 2 percent. This revised study analyzes the impact of taxes on industry location and profit shifting using new panel econometric studies. It also discusses and evaluates new paradigms that have been suggested for the international tax system.
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>> In Brief
Selected chapters and sections are provided for preview only.
2. Corporate Taxation
3. Traditional Tax Doctrine for Foreign Income
4. Residence Taxation for Portfolio Investment Income
5. Multinational Firms in the World Economy [pdf]
6. Agenda for Modest Reform: A Territorial System
History of US Taxation of Foreign Income of US Corporations (Excluding Merchandise Export Income)
History of US Foreign Tax Credit Limitations
History of US Deferral of Current Taxation of Controlled Foreign Corporations
History of US Taxation of Merchandise Export Income
History of US Taxation of Foreign Corporations Doing Business in the United States
History of Source-of-Income Rules Prior to the Tax Reform Act of 1986
Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986
History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations
Methods for Reducing Corporate Income Taxes
A Simple Model of World Portfolio Capital Flows
Temporary Taxes on Portfolio Capital
Conditions for Reimbursement of the Backup Withholding Tax
The Simple Economics of Imperfect Competition
Revenue on Foreign Investment in the United States