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

Daniel N. Shaviro ()
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Daniel N. Shaviro: NYU Law School

No 915, Working Papers from Oxford University Centre for Business Taxation

Abstract: 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.

Keywords: tax law; corporate taxation; international taxation; corporate residence; source; foreign tax credits; controlled foreign corporations; deferral; subpart F (search for similar items in EconPapers)
JEL-codes: H20 H21 H25 (search for similar items in EconPapers)
Date: 2009
New Economics Papers: this item is included in nep-acc and nep-pbe
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Citations: View citations in EconPapers (1)

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