Rethinking Foreign Tax Creditability
AbstractInternational tax policy experts often mistakenly conflate two distinct margins: (1) the overall tax burden on outbound investment, and (2) the marginal reimbursement rate (MRR) for foreign taxes paid, which is 100 percent under a foreign tax credit system, but equals the marginal tax rate for foreign source income under an explicit or implicit deductibility system (such as exemption). From a unilateral national welfare standpoint, whatever the right answer at margin (1), deductibility is clearly optimal, and creditability dangerously over-generous, at margin (2).
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Bibliographic InfoArticle provided by National Tax Association in its journal National Tax Journal.
Volume (Year): 63 (2010)
Issue (Month): 4 (December Citation: 63 National Tax Journal 709-21 (December 2010))
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