Reform Of U S International Taxation


Reform Of U S International Taxation
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Reform Of U S International Taxation


Reform Of U S International Taxation
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Author : Jane G. Gravelle
language : en
Publisher: DIANE Publishing
Release Date : 2011-04

Reform Of U S International Taxation written by Jane G. Gravelle and has been published by DIANE Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-04 with Reference categories.


Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? Contents of this report: The Current System and Possible Revisions; Neutrality, Efficiency, and Competitiveness; 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. Charts and tables. This is a print on demand edition of an important, hard-to-find publication.



Reform Of U S International Taxation


Reform Of U S International Taxation
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Author : David Brumbaugh
language : en
Publisher:
Release Date : 2007

Reform Of U S International Taxation written by David Brumbaugh and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Investments, Foreign categories.


A striking feature of the modern U.S. economy is its growing openness--its increased integration with the rest of the world. The attention of tax policymakers has recently been focused on the growing participation of U.S. firms in the international economy and the increased pressure that engagement places on the U.S. system for taxing overseas business. Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? The current U.S. system for taxing international business is a hybrid. In part the system is based on a residence principle, applying U.S. taxes on a worldwide basis to U.S. firms while granting foreign tax credits to alleviate double taxation. The system, however, also permits U.S. firms to defer foreign-source income indefinitely -a feature that approaches a territorial tax jurisdiction. In keeping with its mixed structure, the system produces a patchwork of economic effects that depend on the location of foreign investment and the circumstances of the firm. Broadly, the system poses a tax incentive to invest in countries with low-tax rates of their own and a disincentive to invest in high-tax countries. In theory, U.S. investment should be skewed towards low-tax countries and away from high-tax locations. Evaluations of the current tax system vary, and so do prescriptions for reform. According to traditional economic analysis, world economic welfare is maximized by a system that applies the same tax burden to prospective (marginal) foreign and domestic investment so that taxes do not distort investment decisions. Such a system possesses "capital export neutrality," and could be accomplished by worldwide taxation applied to all foreign operations along with an unlimited foreign tax credit. In contrast, a system that maximizes national welfare-a system possessing "national neutrality"--Would impose a higher tax burden on foreign investment, thus permitting an overall disincentive for foreign investment. Such a system would impose worldwide taxation, but would permit only a deduction, and not a credit, for foreign taxes. A tax system based on territorial taxation would exempt overseas business investment from U.S. tax. In recent years, several proponents of territorial taxation have argued that changes in the world economy have rendered traditional prescriptions for international taxation obsolete, and instead prescribe territorial taxation as a means of maximizing both world and national economic welfare. For such a system to be neutral, however, capital would have to be completely immobile across locations. A case might be made that such a system is superior to the current hybrid system, but it is not clear that it is superior to other reforms, including not only a movement toward worldwide taxation by ending deferral, but also restricting deductions for costs associated with deferred income or restricting deferral and foreign tax credits for tax havens. This report will not be updated



Reform Of U S International Taxation


Reform Of U S International Taxation
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Author : Congressional Research Service
language : en
Publisher: Createspace Independent Publishing Platform
Release Date : 2017-09-18

Reform Of U S International Taxation written by Congressional Research Service and has been published by Createspace Independent Publishing Platform this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-09-18 with categories.


A striking feature of the modern U.S. economy is its growing openness-its increased integration with the rest of the world. The attention of tax policymakers has recently been focused on the growing participation of U.S. firms in the international economy and the increased pressure that engagement places on the U.S. system for taxing overseas business. Is the current U.S. system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? The current U.S. system for taxing international business is a hybrid. In part, the system is based on a residence principle, applying U.S. taxes on a worldwide basis to U.S. firms while granting foreign tax credits to alleviate double taxation. The system, however, also permits U.S. firms to defer foreign-source income indefinitely-a feature that approaches a territorial tax jurisdiction. In keeping with its mixed structure, the system produces a patchwork of economic effects that depend on the location of foreign investment and the circumstances of the firm. Broadly, the system poses a tax incentive to invest in countries with low tax rates of their own and a disincentive to invest in high-tax countries. In theory, U.S. investment should be skewed toward low-tax countries and away from high-tax locations. Evaluations of the current tax system vary, and so do prescriptions for reform. According to traditional economic analysis, world economic welfare is maximized by a system that applies the same tax burden to prospective (marginal) foreign and domestic investment so that taxes do not distort investment decisions. Such a system possesses capital export neutrality, and could be accomplished by worldwide taxation applied to all foreign operations along with an unlimited foreign tax credit. In contrast, a system that maximizes national welfare-a system possessing national neutrality-would impose a higher tax burden on foreign investment, thus permitting an overall disincentive for foreign investment. Such a system would impose worldwide taxation but would permit only a deduction, and not a credit, for foreign taxes. A tax system based on territorial taxation would exempt overseas business investment from U.S. tax. In recent years, several proponents of territorial taxation have argued that changes in the world economy have rendered traditional prescriptions for international taxation obsolete and instead prescribe territorial taxation as a means of maximizing both world and national economic welfare. For such a system to be neutral, however, capital would have to be completely immobile across locations. A case might be made that such a system is less distorting than the current hybrid system, but it is not clear that it is more likely to achieve policy goals than other reforms, including not only a movement toward worldwide taxation by ending deferral but also proposals to provide a minimum tax and restrict deductions for costs associated with deferred income or restrict deferral and foreign tax credits for tax havens. A House tax proposal, called the "Better Way" tax plan, would not only move to a territorial tax but convert the income tax into a consumption tax. In this case, equity capital would likely be attracted to the United States from foreign countries because of the elimination, in most respects, of a tax on capital income of firms in the United States.



Fixing U S International Taxation


Fixing U S International Taxation
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Author : Daniel N. Shaviro
language : en
Publisher: Oxford University Press
Release Date : 2014-02-05

Fixing U S International Taxation written by Daniel N. Shaviro and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-02-05 with Law categories.


International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.



Reform Of U S International Taxation


Reform Of U S International Taxation
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Author : Congressional Research Congressional Research Service
language : en
Publisher: CreateSpace
Release Date : 2014-12-01

Reform Of U S International Taxation written by Congressional Research Congressional Research Service and has been published by CreateSpace this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-12-01 with categories.


A striking feature of the modern U.S. economy is its growing openness-its increased integration with the rest of the world. The attention of tax policy makers has recently been focused on the growing participation of U.S. firms in the international economy and the increased pressure that engagement places on the U.S. system for taxing overseas business. Is the current U.S. system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? The current U.S. system for taxing international business is a hybrid. In part, the system is based on a residence principle, applying U.S. taxes on a worldwide basis to U.S. firms while granting foreign tax credits to alleviate double taxation. The system, however, also permits U.S. firms to defer foreign-source income indefinitely-a feature that approaches a territorial tax jurisdiction. In keeping with its mixed structure, the system produces a patchwork of economic effects that depend on the location of foreign investment and the circumstances of the firm. Broadly, the system poses a tax incentive to invest in countries with low tax rates of their own and a disincentive to invest in high-tax countries. In theory, U.S. investment should be skewed toward low-tax countries and away from high-tax locations. Evaluations of the current tax system vary, and so do prescriptions for reform. According to traditional economic analysis, world economic welfare is maximized by a system that applies the same tax burden to prospective (marginal) foreign and domestic investment so that taxes do not distort investment decisions. Such a system possesses capital export neutrality, and could be accomplished by worldwide taxation applied to all foreign operations along with an unlimited foreign tax credit. In contrast, a system that maximizes national welfare-a system possessing national neutrality-would impose a higher tax burden on foreign investment, thus permitting an overall disincentive for foreign investment. Such a system would impose worldwide taxation but would permit only a deduction, and not a credit, for foreign taxes. A tax system based on territorial taxation would exempt overseas business investment from U.S. tax. In recent years, several proponents of territorial taxation have argued that changes in the world economy have rendered traditional prescriptions for international taxation obsolete and instead prescribe territorial taxation as a means of maximizing both world and national economic welfare. For such a system to be neutral, however, capital would have to be completely immobile across locations. A case might be made that such a system is less distorting than the current hybrid system, but it is not clear that it is more likely to achieve policy goals than other reforms, including not only a movement toward worldwide taxation by ending deferral but also proposals to provide a minimum tax and restrict deductions for costs associated with deferred income or restrict deferral and foreign tax credits for tax havens.



Reform Of U S International Taxation


Reform Of U S International Taxation
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Author : Jane Gravelle
language : en
Publisher:
Release Date : 2015

Reform Of U S International Taxation written by Jane Gravelle and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with categories.


This report describes and assesses the principal prescriptions that have been offered for broad reform of the international system. It begins with an overview of current law and possible revisions. It then sets the framework for considering economic efficiency as well as tax shelter activities. Finally, it reviews alternative approaches to revision in light of those issues.



Introduction To U S International Taxation


Introduction To U S International Taxation
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Author : Paul R. McDaniel
language : en
Publisher: Springer
Release Date : 1981-06-17

Introduction To U S International Taxation written by Paul R. McDaniel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1981-06-17 with Business & Economics categories.


This book presents the basic priciples and rules of the United States international tax system in a relatively brief form. The purpose is to provide an overview of the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work or carry on a trade or business in the US or abroad.



Hearing On The Impact Of International Tax Reform On U S Competitiveness


Hearing On The Impact Of International Tax Reform On U S Competitiveness
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Author : United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures
language : en
Publisher:
Release Date : 2006

Hearing On The Impact Of International Tax Reform On U S Competitiveness written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Competition categories.




U S International Tax System


U S International Tax System
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Author : Holly Lanford
language : en
Publisher: Nova Science Publishers
Release Date : 2014

U S International Tax System written by Holly Lanford and has been published by Nova Science Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Income tax categories.


On July 22, 2014, the Senate Committee on Finance held a public hearing on the taxation of cross-border income. This book, prepared by the staff of the Joint Committee on Taxation for the hearing, includes a description of present law, background on recent global activity related to the taxation of cross-border income, and descriptions and a comparison of recent proposals to reform the U.S. international tax system.



Borderline Case


Borderline Case
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Author : National Research Council
language : en
Publisher: National Academies Press
Release Date : 1998-02-05

Borderline Case written by National Research Council and has been published by National Academies Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-02-05 with Political Science categories.


The growing integration of world markets for capital and goods, coupled with the rise of instantaneous worldwide communication, has made identification of corporations as "American," "Dutch," or "Japanese" extremely difficult. Yet tax treatment does depend of where a firm is chartered. And, as Borderline Case documents, there is little doubt that tax rules for firms doing business in several nationsâ€"firms that account for more than three-quarters of corporate R&D spending in the United Statesâ€"have substantial effects on corporate decisionmaking and, ultimately, U.S. competitiveness. This book explores the impact of the U.S. tax code and its incentives on the international activities of U.S.- and foreign-based firms: basic research outlays, expenditures on product and process development, and plant and equipment investment. The authors include industry experts from large multinational firms in technology and pharmaceuticals, academic researchers who have explored the quantitative impact of tax provisions on R&D, and tax policy analysts who have examined international tax rules in the broader context of tax reform. These experts look at how corporate investment and R&D are shaped by specific tax provisions, such as the definition of taxable income, relative tax burdens on domestic and foreign business, taxation of earnings repatriated to the United States, deductibility of expenses of worldwide operations, and U.S. corporate taxes relative to other countries. The volume explores prescriptions and prospects for tax reform and reviews major reform proposals and their implications for the behavior of multinational business.