U. S. Taxation of International Income: Blueprint for Reform

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Hardcover 1st UNUSED, BRAND NEW, NOT EX-LIBRARY, Hardcover ISBN: 0881321346 First Edition, 283 pages. (The US system of taxing international income flows was conceived in the ... 1920s and crystallized by the 1950s, when taxation of international transactions was seen as totally distinct from taxation ofdomestic income. The main concern during that time was division of revenue between taxing authorities, not competition on a global scale. US corporations dominated world commerce and investment, andforeign investment in the United States was minimal. The world economy has changed dramatically since the 1950s, but the basic structure of US taxation of international income remains much the same. Thisstudy offers a blueprint for reforming US taxation of international income to accommodate the economic realities of the 1990s, especially heightened competition from Europe and Japan. A guiding theme is to ensure that the tax. system helps make the United States a hospitable location for R&D facilities and other he Read more Show Less

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Table of Contents

Preface
Acknowledgments
1 Introduction and Overview 1
The US Role in the World Economy: Four Decades of Change 1
US Multinationals and the Internationalization of the US Economy 4
The Rise of High Technology 8
Tax Policy Implications 14
2 Corporate Taxation: Durable Anachronism 19
The Incidence of the Corporate Income Tax 22
Relevance to International Tax Issues 28
Recommended US Policy 39
3 Traditional Tax Doctrine for International Business Income 47
Capital Export Neutrality 49
National Neutrality 55
Capital Import Neutrality 57
The Future Debate 60
4 A New Tax Policy for Portfolio Investment Income 63
The Rise of Portfolio Capital 63
Applying CEN Logic to Portfolio Income 65
Residence-Only Taxation of Portfolio Income 66
Cooperation Against Tax Avoidance 68
Revenue Considerations 71
5 Multinational Firms in the World Economy 77
Strategic Arguments for Intervention 78
A Model of Economic Profits and Headquarters Costs 86
Restrictive Policies and National Prosperity 90
Tax Policy Implications 93
6 Emerging Tax Issues for International Business Income 95
Technology Export Neutrality 95
Source-of-Income Rules 98
Allocation-of-Expense Rules 100
Transfer Prices 107
Discrimination Against Multinational Firms 122
Taxation of Export Income 123
State Taxation of International Income 129
7 A New Tax Policy for Multinational Firms 131
US Business Taxation and American Prosperity 135
An Open International System 147
Revenue Considerations 157
US Tax Treaty Policy 169
App. A: Legal Summary of US Taxation of International Income 175
A.1 History of US Taxation of Foreign Income of US Corporations Excluding Merchandise Export Income 176
A.2 History of US Foreign Tax Credits Limitations 187
A.3 History of US Deferral of Current Taxation of Controlled Foreign Corporations 189
A.4 History of US Taxation of Merchandise Export Income 190
A.5 History of US Taxation of Foreign Corporations Doing Business in the United States 195
A.6 History of Source-of-Income Rules Prior to the Tax Reform Act of 1986 201
A.7 Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986 203
A.8 Comparison of Allocation-of-Expense Rules Before and After the Tax Reform Act of 1986 208
A.9 History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations 212
A.10 Main Provisions of US Bilateral Income Tax Treaties 216
App. B: A Simple Model of World Portfolio Capital Flows 221
App. C: The Simple Economics of Imperfect Competition 225
App. D: Technology Export Neutrality 231
App. E: Allocation of Interest Expense - The Debt Purpose and Fungibility Paradigms and Proposals for Reform 235
App. F: The Virtues and Vices of an Incremental R&D Credit 243
References 253
Index 265
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