U.S. taxation of foreign income

著者

書誌事項

U.S. taxation of foreign income

Gary Clyde Hufbauer & Ariel Assa

Peterson Institute for International Economics, 2007

タイトル別名

US taxation of foreign income

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注記

Includes bibliographical references (p. 297-307) and index

内容説明・目次

内容説明

Since 1992, new issues have arisen in international taxation-for example, taxation of electronic commerce, novel means of shielding passive income, the World Trade Organization (WTO) debate over the foreign sales corporation and subsequent passage of the American Jobs Creation Act of 2004, the problem of corporate inversions, and alleged "earnings stripping" by foreign-based multinational enterprises (MNEs) operating in the United States. In the meantime, US-based MNEs operating abroad have used a variety of methods to cut the effective US tax on repatriated foreign source income to around 2 percent. This revised study analyzes the impact of taxes on industry location and profit shifting using new panel econometric studies. It also discusses and evaluates new paradigms that have been suggested for the international tax system.

目次

  • 1: Introduction
  • 2: Corporate Taxation
  • 3: Traditional Tax Doctrine for International Business Income
  • 4: Residence Taxation for Portfolio Investment Income
  • 5: Multinational Firms in the World Economy
  • 6: Electronic Commerce
  • 7: Agenda for Modest Reform: A Territorial System
  • 8: A New Model for Federal Business Taxation
  • Appendices
  • A.1 History of US Taxation of Foreign Income of US Corporations
  • A.2 History of US Foreign Tax Credit Limitations
  • A.3 History of US Deferral of Current Taxation of Controlled Foreign Corporations
  • A.4 History of US Taxation of Merchandise Export Income
  • A.5 History of US Taxation of Foreign Corporations Doing Business in the United States
  • A.6 History of Source-of-Income Rules Prior to the Tax Reform Act of 1986
  • A.7 Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986
  • A.8 Allocation-of-Expenses Rules
  • A.9 History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations
  • B Methods for Reducing Corporate Income Taxes
  • C.1 A Simple Model of World Portfolio Capital Flows
  • C.2 Temporary Taxes on Portfolio Capital
  • C.3 Conditions for Reimbursement of the Back-up Withholding Tax
  • D The Simple Economics of Imperfect Competition
  • E Federal Revenue Demands.

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