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Overview"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." Full Product DetailsAuthor: Gary Clyde Hufbauer , Ariel AssaPublisher: The Peterson Institute for International Economics Imprint: The Peterson Institute for International Economics Dimensions: Width: 15.40cm , Height: 1.70cm , Length: 22.80cm Weight: 0.478kg ISBN: 9780881324051ISBN 10: 0881324051 Pages: 320 Publication Date: 15 October 2007 Audience: General/trade , General Format: Paperback Publisher's Status: Active Availability: Out of stock  The supplier is temporarily out of stock of this item. It will be ordered for you on backorder and shipped when it becomes available. Language: English Table of Contents1: Introduction; 2: Corporate Taxation; 3: Traditional Tax Doctrine for International Business Income; 4: Residence Taxation for Portfolio Investment Income; 5: Multinational Firms in the World Economy; 6: Electronic Commerce; 7: Agenda for Modest Reform: A Territorial System; 8: A New Model for Federal Business Taxation; Appendices; A.1 History of US Taxation of Foreign Income of US Corporations; A.2 History of US Foreign Tax Credit Limitations; A.3 History of US Deferral of Current Taxation of Controlled Foreign Corporations; A.4 History of US Taxation of Merchandise Export Income; A.5 History of US Taxation of Foreign Corporations Doing Business in the United States; A.6 History of Source-of-Income Rules Prior to the Tax Reform Act of 1986; A.7 Comparison of Source-of-Income Rules Before and After the Tax Reform Act of 1986; A.8 Allocation-of-Expenses Rules; A.9 History of Rules for Intercompany Pricing Between US and Affiliated Foreign Corporations; B Methods for Reducing Corporate Income Taxes; C.1 A Simple Model of World Portfolio Capital Flows; C.2 Temporary Taxes on Portfolio Capital; C.3 Conditions for Reimbursement of the Back-up Withholding Tax; D The Simple Economics of Imperfect Competition; E Federal Revenue Demands.ReviewsA studious, heavily researched assessment, highly recommended especially for anyone involved in crafting American tax policy. Midwest Book Review Author InformationGary Clyde Hufbauer, Reginald Jones Senior Fellow since 1992, was formerly the Maurice Greenberg Chair and Director of Studies at the Council on Foreign Relations (1996-98), the Marcus Wallenberg Professor of International Finance Diplomacy at Georgetown University (1985-92), senior fellow at the Institute (1981-85), deputy director of the International Law Institute at Georgetown University (1979-81); deputy assistant secretary for international trade and investment policy of the US Treasury (1977-79); and director of the international tax staff at the Treasury (1974-76). Ariel Assa is a tax counsel for JP Morgan Chase & Co. in New York City. He was a tax attorney at the law firms of Willkie, Farr & Gallagher LLP in New York City (2003-07) and Herzog, Fox & Neeman in Tel Aviv (1999-2001). He also served as a tax agent in Israel's Income Tax Authority (1994-99) and an assistant professor in several tax courses at Tel Aviv University (1996-2001). He earned his law, accounting, and MBA degrees from Tel Aviv University and is a graduate of the LLM program in taxation at Georgetown University Law Center (2002). Tab Content 6Author Website:Countries AvailableAll regions |
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