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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

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    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.
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    Cited by:

    1. Desai, Mihir A. & Dharmapala, Dhammika, 2010. "Do Strong Fences Make Strong Neighbors?," National Tax Journal, National Tax Association, 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

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