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 rate 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.
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