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Cover -- Title Page -- Copyright Page -- Table of Contents -- Chapter 1 -- Overview of U.S. Corporate International Taxation -- Summary -- U.S. Outbound Tax Concepts -- U.S. Inbound Tax Concepts -- Other fundamental U.S. international tax concepts -- International tax fundamental concepts -- Recognition of income -- Introduction of International Tax Provisions enacted by the TCJA -- Introduction and listing of U.S. international tax provisions -- U.S. Export Tax Incentive through an IC-DISC -- Chapter 2 -- Foreign Branches -- Operating through a foreign branch -- summary

As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today.The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influenc

International Taxation of Banking' introduces and analyses the international tax issues which relate to international banking activities. Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry, and it includes the structures used in bank treasury operations and transfer pricing issues for multinational banking groups

As a united global economy evolves, economists and policymakers are forced to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies. The contributors to this volume are Rosanne Altshuler, Alan J. Auerbach, Neil Bruce, Timothy Goodspeed, Roger H. Gordon, Harry Grubert, Bronwyn H. Hall, David Harris, Kevin Hassett, James R. Hines Jr., Roy D. Hogg, Joosung Jun, Jeffrey K. Mackie-Mason, Jack M. Mintz, Randall Morck, John Mutti, T. Scott Newlon, James M. Poterba, Joel Slemrod, Deborah Swenson, G. Peter Wilson, and Bernard Yeung

Intro -- CORPORATE AND INTERNATIONAL TAXATION: ANALYSES AND REFORMS -- CORPORATE AND INTERNATIONAL TAXATION: ANALYSES AND REFORMS -- CONTENTS -- PREFACE -- Chapter 1 REFORM OF U.S. INTERNATIONAL TAXATION: ALTERNATIVES -- SUMMARY -- THE CURRENT SYSTEM AND POSSIBLE REVISIONS -- The System's Structure -- Possible Revisions -- NEUTRALITY, EFFICIENCY, AND COMPETITIVENESS -- Understanding Capital Export Neutrality, Capital Import Neutrality,and National Neutrality -- Capital Ownership Neutrality -- ASSESSING THE EXISTING TAX SYSTEM -- TERRITORIAL TAXATION: THE DIVIDEND EXEMPTION PROPOSAL -- A RESIDENCE-BASED SYSTEM IN PRACTICE -- PRESIDENT OBAMA'S PROPOSALS TO RESTRICT DEFERRAL AND CROSS-CREDITING -- TAX HAVENS: ISSUES AND POLICY OPTIONS -- GENERAL REFORMS OF THE CORPORATE TAX AND IMPLICATIONS FOR INTERNATIONAL TAX TREATMENT -- ACKNOWLEDGMENTS -- End Notes -- Chapter 2 TAX CUTS ON REPATRIATION EARNINGS AS ECONOMIC STIMULUS: AN ECONOMIC ANALYSIS -- SUMMARY -- THE U.S. INTERNATIONAL TAX SYSTEM -- REPATRIATED EARNINGS PROVISIONS IN THE AMERICAN JOBS CREATION ACT -- IMPACTS OF A REDUCTION IN THE TAX ON REPATRIATED EARNINGS -- Impact on Repatriated Earnings -- Impact on Economic Growth -- Use of Repatriated Earnings and Economic Stimulus -- Exchange Rate Adjustments and Economic Stimulus -- End Notes -- Chapter 3 CORPORATE TAX REFORM: ISSUES FOR CONGRESS -- SUMMARY -- INTRODUCTION -- THE CORPORATE TAX AS A REVENUE SOURCE -- Magnitude and Historical Pattern -- The Role of the Corporate Tax in Backstopping the Individual Tax -- BEHAVIORAL RESPONSES AND REVENUE MAXIMIZING TAX RATE -- Theoretical Issues -- Empirical Analysis -- Brill and Hassett Study -- Clausing Study -- CROSS COUNTRY INVESTMENT ESTIMATES: THE DJANKOV STUDY -- Theoretical Issues -- Empirical Analysis -- DISTRIBUTIONAL EFFECTS -- The Harberger and Randolph Studies

This book provides an introduction to the US law of international taxation. It summarizes the law, offering some attention to the purposes of the various legal rules. The book is divided into three parts. First it gives an introduction to the fundamentals of US international taxation and the source rules. The second part addresses the US activities of foreign taxpayers, i.e. investment and business activities carried on by nonresident individuals and foreign corporations in the US. Special attention is given to the branch profit tax and the provisions affecting foreign investment in US real estate. The third part is directed at foreign activities of US citizens and residents

This paper analyzes Pareto-efficient international tax regimes. Because every country faces its own national budget constraint, the Diamond-Mirrlees production-efficiency theorem, which underlies key tenets of policy advice in international taxation—the desirability of destination basis for commodity taxation, of the residence principle for capital income taxation, and of free trade—does not apply. The paper establishes conditions—relating to the availability of explicit or implicit devices for reallocating tax revenues across countries—under which production efficiency is nevertheless desirable, and characterizes the precise ways in which Pareto-efficient international taxation may require violation of established tenets.