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Taxing International Income: An Analysis of the U.S. System and Its Economic Premises

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  • David F. Bradford
  • Hugh J. Ault

Abstract

This paper describes the basic U.S. legal rules that govern the taxation of international transactions and explores the economic policies or principles they reflect. Particular attention is paid to the changes made by the Tax Reform Act of 1986, but it is impossible to understand the 1986 Act changes without placing them in the context of the general taxing system applicable to international transactions. The exposition is intended to be intelligible to readers with either legal or economic training.

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Bibliographic Info

Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 3056.

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Date of creation: Dec 1990
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Publication status: published as Taxation in the Global Economy, edited by Assaf Razin and Joel Slemrod, pp. 11-46. Chicago: The University of Chicago Press, 1990.
Handle: RePEc:nbr:nberwo:3056

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References

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  1. Mutti, John & Grubert, Harry, 1985. "The taxation of capital income in an open economy: the importance of resident-nonresident tax treatment," Journal of Public Economics, Elsevier, Elsevier, vol. 27(3), pages 291-309, August.
  2. Dixit, Avinash, 1985. "Tax policy in open economies," Handbook of Public Economics, Elsevier, in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 1, chapter 6, pages 313-374 Elsevier.
  3. Feldstein, Martin & Hartman, David, 1979. "The Optimal Taxation of Foreign," The Quarterly Journal of Economics, MIT Press, MIT Press, vol. 93(4), pages 613-29, November.
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Cited by:
  1. Vijay Jog & Jianmin Tang, 2001. "Tax Reforms, Debt Shifting and Tax Revenues: Multinational Corporations in Canada," International Tax and Public Finance, Springer, Springer, vol. 8(1), pages 5-25, January.
  2. Hans-Werner Sinn, 1990. "Taxation and the Birth of Foreign Subsidiaries," NBER Working Papers 3519, National Bureau of Economic Research, Inc.
  3. Desai, Mihir A. & Hines Jr., James R., 1999. ""Basket cases": Tax incentives and international joint venture participation by American multinational firms," Journal of Public Economics, Elsevier, Elsevier, vol. 71(3), pages 379-402, March.
  4. Boss, Alfred, 1990. "Kapitaleinkommensbesteuerung und internationale Kapitalbewegungen," Kiel Working Papers 426, Kiel Institute for the World Economy.
  5. Frenkel, Jacob A & Razin, Assaf, 1987. "Fiscal Policies and the World Economy; An Intertemporal Approach (Cambridge, Mass.: MIT Press, 1987)," MPRA Paper 20438, University Library of Munich, Germany.
  6. John Whalley, 2001. "Puzzles Over International Taxation of Cross Border Flows of Capital Income," NBER Working Papers 8662, National Bureau of Economic Research, Inc.
  7. Rosanne Altshuler, 2000. "Recent Developments in the Debate on Deferral," Departmental Working Papers, Rutgers University, Department of Economics 200013, Rutgers University, Department of Economics.
  8. Philippe Thalmann & Lawrence Goulder & François Delorme, 1996. "Assessing the international spillover effects of capital income taxation," International Tax and Public Finance, Springer, Springer, vol. 3(4), pages 449-478, October.
  9. Alfons Weichenrieder, 1996. "Anti-tax-avoidance provisions and the size of foreign direct investment," International Tax and Public Finance, Springer, Springer, vol. 3(1), pages 67-81, January.
  10. Rosanne Altshuler & Harry Grubert, 1998. "Multinational Financial Policy and the Cost of Capital: The Many Roads Home," Departmental Working Papers, Rutgers University, Department of Economics 199807, Rutgers University, Department of Economics.
  11. Rosanne Altshuler & Harry Grubert, 1996. "Balance Sheets, Multinational Financial Policy, and the Cost of Capital at Home and Abroad," NBER Working Papers 5810, National Bureau of Economic Research, Inc.
  12. Joel Slemrod, 1994. "Free-Trade Taxation and Protectionist Taxation," NBER Working Papers 4902, National Bureau of Economic Research, Inc.
  13. Jason Cummins & R. Glenn Hubbard, 1995. "The Tax Sensitivity of Foreign Direct Investment: Evidence from Firm-Level Panel Data," NBER Chapters, in: The Effects of Taxation on Multinational Corporations, pages 123-152 National Bureau of Economic Research, Inc.
  14. Slemrod, J., 1990. "The Impact Of The Tax Reform Act Of 1986 On Foreign Direct Investment To And From The United States," Working Papers, Research Seminar in International Economics, University of Michigan 256, Research Seminar in International Economics, University of Michigan.

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