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Reform of U.S. International Taxation - Alternatives (Paperback)
Loot Price: R337
Discovery Miles 3 370
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Reform of U.S. International Taxation - Alternatives (Paperback)
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Loot Price R337
Discovery Miles 3 370
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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.
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