IDEAS home Printed from
   My bibliography  Save this paper

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


  • Daniel N. Shaviro

    () (NYU Law School)


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.

Suggested Citation

  • Daniel N. Shaviro, 2009. "Planning and Policy Issues Raised by the Structure of the U.S. International Tax Rules," Working Papers 0915, Oxford University Centre for Business Taxation.
  • Handle: RePEc:btx:wpaper:0915

    Download full text from publisher

    File URL:
    Download Restriction: no

    References listed on IDEAS

    1. Altshuler, Rosanne & Grubert, Harry, 2003. "Repatriation taxes, repatriation strategies and multinational financial policy," Journal of Public Economics, Elsevier, vol. 87(1), pages 73-107, January.
    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.
    Full references (including those not matched with items on IDEAS)


    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.

    Cited by:

    1. Desai, Mihir A. & Dharmapala, Dhammika, 2010. "Do Strong Fences Make Strong Neighbors?," National Tax Journal, National Tax Association;National Tax Journal, vol. 63(4), pages 723-740, December.

    More about this item


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

    JEL classification:

    • H20 - Public Economics - - Taxation, Subsidies, and Revenue - - - General
    • H21 - Public Economics - - Taxation, Subsidies, and Revenue - - - Efficiency; Optimal Taxation
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

    NEP fields

    This paper has been announced in the following NEP Reports:


    Access and download statistics


    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:btx:wpaper:0915. See general information about how to correct material in RePEc.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: (Dongxian Guo). General contact details of provider: .

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service hosted by the Research Division of the Federal Reserve Bank of St. Louis . RePEc uses bibliographic data supplied by the respective publishers.