The Economic Case For Foreign Tax Credits for Cash Flow Taxes
AbstractSince 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 InfoArticle provided by National Tax Association in its journal National Tax Journal.
Volume (Year): 51 (1998)
Issue (Month): n. 1 (March Citation: 51 National Tax Journal 1-22 (March 1998))
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- 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.
- Ernst Fehr & Wolfgang Wiegard, 2001. "The Incidence of an Extended Ace Corporation Tax," CESifo Working Paper Series 484, CESifo Group Munich.
- Christian Keuschnigg & Martin Dietz, 2007.
"A growth oriented dual income tax,"
International Tax and Public Finance,
Springer, vol. 14(2), pages 191-221, April.
- Paolo M. Panteghini, 2005.
"Asymmetric Taxation under Incremental and Sequential Investment,"
Journal of Public Economic Theory,
Association for Public Economic Theory, vol. 7(5), pages 761-779, December.
- Paolo Panteghini, 2002. "Asymmetric Taxation under Incremental and Sequential Investment," CESifo Working Paper Series 717, CESifo Group Munich.
- Juan José Echavarría & George R. Zodrow, 2003. "Foreign direct investment and tax structure in Colombia," IDB Publications 5598, Inter-American Development Bank.
- 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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