U.S. taxation of international income : blueprint for reform /
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| Author / Creator: | Hufbauer, Gary Clyde |
|---|---|
| Imprint: | Washington, DC : Institute for International Economics, 1992. |
| Description: | xv, 276 p. ; 23 cm. |
| Language: | English |
| Subject: | |
| Format: | Print Book |
| URL for this record: | http://pi.lib.uchicago.edu/1001/cat/bib/1318321 |
Table of Contents:
- Preface / C. Fred Bergsten
- 1. Introduction and Overview. The US Role in the World Economy: Four Decades of Change. US Multinationals and the Internationalization of the US Economy. The Rise of High Technology. Tax Policy Implications
- 2. Corporate Taxation: Durable Anachronism. The Incidence of the Corporate Income Tax. Relevance to International Tax Issues. Recommended US Policy
- 3. Traditional Tax Doctrine for International Business Income. Capital Export Neutrality. National Neutrality. Capital Import Neutrality. The Future Debate
- 4. A New Tax Policy for Portfolio Investment Income. The Rise of Portfolio Capital. Applying CEN Logic to Portfolio Income. Residence-Only Taxation of Portfolio Income. Cooperation Against Tax Avoidance. Revenue Considerations
- 5. Multinational Firms in the World Economy. Strategic Arguments for Intervention. A Model of Economic Profits and Headquarters Costs. Restrictive Policies and National Prosperity. Tax Policy Implications
- 6. Emerging Tax Issues for International Business Income. Technology Export Neutrality. Source-of-Income Rules. Allocation-of-Expense Rules. Transfer Prices. Discrimination Against Multinational Firms. Taxation of Export Income. State Taxation of International Income
- 7. A New Tax Policy for Multinational Firms. US Business Taxation and American Prosperity. An Open International System. Revenue Considerations. US Tax Treaty Policy. App. A: Legal Summary of US Taxation of International Income. A.1. History of US Taxation of Foreign Income of US Corporations Excluding Merchandise Export Income. A.2. History of US Foreign Tax Credits Limitations. A.3. History of US Deferral of Current Taxation of Controlled Foreign Corporations. A.4. History of US Taxation of Merchandise Export Income. A.5. History of US Taxation of Foreign Corporations Doing Business in the United States. A.6. History of Source-of-Income Rules Prior to the Tax Reform Act of 1986. A.7. Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986. A.8. Comparison of Allocation-of-Expense Rules Before and After the Tax Reform Act of 1986. A.9. History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations. A.10. Main Provisions of US Bilateral Income Tax Treaties. App. B: A Simple Model of World Portfolio Capital Flows
- App. C: The Simple Economics of Imperfect Competition
- App. D: Technology Export Neutrality
- App. E: Allocation of Interest Expense - The Debt Purpose and Fungibility Paradigms and Proposals for Reform
- App. F: The Virtues and Vices of an Incremental R&D Credit.