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The Economic Case For Foreign Tax Credits for Cash Flow Taxes

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  • McLure, Charles E. Jr.
  • Zodrow, George R.

Abstract

Since consumption-based direct taxes typically include a business-level cash flow tax (CFT), any foreign country considering such a tax system faces the risk that a CFT might not be eligible for foreign tax credits in the United States. In this paper, we present the economic case for granting creditability for CFTs, arguing that such treatment is appropriate under current U.S. law, regardless of whether one applies the fairly general wording of the statute or the highly mechanical tests of the regulations. Moreover, we argue that, if this position is rejected, U.S. law and/or regulations should be changed to make CFTs creditable.

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Bibliographic Info

Article provided by National Tax Association in its journal National Tax Journal.

Volume (Year): 51 (1998)
Issue (Month): n. 1 (March)
Pages: 1-22

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Handle: RePEc:ntj:journl:v:51:y:1998:i:n._1:p:1-22

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Cited by:
  1. Ernst Fehr & Wolfgang Wiegard, 2001. "The Incidence of an Extended Ace Corporation Tax," CESifo Working Paper Series 484, CESifo Group Munich.
  2. Paolo Panteghini, 2002. "Asymmetric Taxation under Incremental and Sequential Investment," CESifo Working Paper Series 717, CESifo Group Munich.
  3. Christian Keuschnigg & Martin Dietz, 2007. "A growth oriented dual income tax," International Tax and Public Finance, Springer, vol. 14(2), pages 191-221, April.
  4. Harry Grubert, 2004. "Tax Credits, Source Rules, Trade and Electronic Commerce: Behavioral Margins and the Design of International Tax Systems," CESifo Working Paper Series 1366, CESifo Group Munich.
  5. George Zodrow, 2006. "Capital Mobility and Source-Based Taxation of Capital Income in Small Open Economies," International Tax and Public Finance, Springer, vol. 13(2), pages 269-294, May.

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