"A studious, heavily researched assessment, highly recommended especially for anyone involved in crafting American Tax Policy." Midwest Book Review
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US Taxation of Foreign Income
by Gary Clyde Hufbauer
and
Ariel Assa
October 2007
• 319 pp. ISBN paper 978-0-88132-405-1 • $20.21
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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.
>> In Brief
Contents
Chapters (in pdf format) are provided for preview only.
Preface
Acknowledgments
1. Introduction [pdf]
2. Corporate Taxation
[pdf]
3. Traditional Tax Doctrine for Foreign Income [pdf]
4. Residence Taxation for Portfolio Investment Income [pdf]
5. Multinational Firms in the World Economy [pdf]
6. Agenda for Modest Reform: A Territorial System [pdf]
Appendix A1
History of US Taxation of Foreign Income of US Corporations (Excluding Merchandise Export Income)
Appendix A2
History of US Foreign Tax Credit Limitations
Appendix A3
History of US Deferral of Current Taxation of Controlled Foreign Corporations
Appendix A4
History of US Taxation of Merchandise Export Income
Appendix A5
History of US Taxation of Foreign Corporations Doing Business in the United States
Appendix A6
History of Source-of-Income Rules Prior to the Tax Reform Act of 1986
Appendix A7
Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986
Appendix A8
Allocation-of-Expenses Rules
Appendix A9
History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations
Appendix B
Methods for Reducing Corporate Income Taxes
Appendix C1
A Simple Model of World Portfolio Capital Flows
Appendix C2
Temporary Taxes on Portfolio Capital
Appendix C3
Conditions for Reimbursement of the Backup Withholding Tax
Appendix D
The Simple Economics of Imperfect Competition
Appendix E
Electronic Commerce
Appendix F
Revenue on Foreign Investment in the United States
References
Index
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