Law Commons^™

U.S. Tax Reform: Full-Inclusion Over Territorial System Compelling, Jeffrey M. Kadet

Articles

The territorial system strongly lobbied for by U.S. multinational corporations that stand to benefit from that system is not what’s best for our country or our society. It is bad tax policy for many reasons, including the strong motivation it provides our multinational corporations to continue moving operations, jobs, risks, and assets outside the United States to achieve double non-taxation. A worldwide full-inclusion system would severely curtail or completely eliminate that strong motivation because double nontaxation would no longer be possible because of a current federal tax on all earnings that cannot be eliminated through any tax schemes or creative …

Worldwide Tax Reform: Reversing The Race To The Bottom, Jeffrey M. Kadet

Articles

The OECD Base Erosion and Profit Shifting Project is now under way, its mission being to suggest ways that countries can work together and amend their domestic laws to combat the corporate profit shifting that has so affected the tax bases of many countries.

The only way to truly eliminate corporate profit shifting is to eliminate the strong motivation multinational enterprises have to achieve "double nontaxation" by engaging in profit shifting. By being subject to current home-country taxation on its worldwide earnings, a multinational cannot achieve double nontaxation. That will eliminate or significantly reduce its motivation to engage in complicated …