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Planning and Policy Issues Raised by the Structure of the U.S. International Tax Rules

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  • Daniel N. Shaviro

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    (NYU Law School)

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    Abstract

    The U.S. international income tax rules, which govern the U.S. tax treatment of multinational companies, employ five key concepts: corporate residence, source of income, foreign tax credits with limits, deferral, and subpart F. This paper, which is a draft version of chapter 2 of a book in progress entitled Fixing the U.S. International Tax Rules, explores the tax planning and tax policy issues raised in practice by each of these concepts, focusing in particular on how, why, to what extent, and with what consequences each of them runs into difficulty in practice.

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    Bibliographic Info

    Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 0915.

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    Date of creation: 2009
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    Handle: RePEc:btx:wpaper:0915

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    Related research

    Keywords: tax law; corporate taxation; international taxation; corporate residence; source; foreign tax credits; controlled foreign corporations; deferral; subpart F;

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    1. Rosanne Altshuler & Harry Grubert, 2002. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," Departmental Working Papers 200009, Rutgers University, Department of Economics.
    2. Harry Grubert, 2009. "Foreign Taxes, Domestic Income, and the Jump in the Share of Multinational Company Income Abroad," Working Papers 0926, Oxford University Centre for Business Taxation.
    3. Harry Grubert, 2009. "MNC Dividends, Tax Holidays and the Burden of the Repatriation Tax: Recent Evidence," Working Papers 0927, Oxford University Centre for Business Taxation.
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