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Fixing U.S. International Taxation

Fixing U.S. International Taxation

Author: Daniel N. Shaviro
Publisher: Oxford University Press USA
ISBN: 9780199359752
Published In: February 2014
Format: Hardback , 224 pages
Jurisdiction: U.S. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents
Author

Details

Offers a major rethinking of basic international tax policy principles
Provides a clear conceptual overview of U.S. international tax law and international tax policy thinking over the last 50 years
Explains main incentive effects created by the U.S. international tax rules
Addresses the current fundamental theoretical mis-framing of crucial questions, issues, and distinctions in international tax law
Proposes both radical and modest changes to improve the international tax system on multiple levels

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.

Readership: Policymakers, and academics in the US, and in other countries. Students of international tax law and policy that are offered at law schools, business schools, and in specialized economics courses throughout the world.

Acknowledgments
1. Introduction and Overview
Part One: The Rules and Their Main Effects
2. The Main Building Blocks of U.S. International Taxation
3. Planning and Policy Issues Under the Existing U.S. Rules
Part Two: Developing and Applying a Policy Framework
4. The Global Welfare Perspective
5. The Unilateral National Welfare Perspective
6 What Is To Be Done?
Bibliography
Index

Daniel N. Shaviro is the Wayne Perry Professor of Taxation at New York University School of Law. Prof. Shaviro's scholarly work examines tax policy, budget policy, and entitlements issues. Before entering teaching of law, he spent three years in private practice at Caplin & Drysdale, a leading tax specialty firm, and three years as Legislation Attorney at the Joint Congressional Committee on Taxation, where he worked extensively on the Tax Reform Act of 1986. Books he has published include: Decoding the U.S. Corporate Tax (2009); Taxes, Spending, and the U.S. Government's March Towards Bankruptcy (2007); Who Should Pay for Medicare?(2004); Making Sense of Social Security Reform (2000); When Rules Change: An Economic and Political Analysis of Transition Relief and Retroactivity (2000); and Do Deficits Matter? (1997). He holds an AB summa cum laude from Princeton University and a JD from Yale Law School.