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Full-Text Articles in Law
Two Cheers For The Foreign Tax Credit, Even In The Beps Era, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Two Cheers For The Foreign Tax Credit, Even In The Beps Era, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship
Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this article, we favor worldwide taxation if it is real worldwide taxation – i.e., a non-deferred U.S. tax is imposed on all foreign income of U.S. residents at the time the income in earned. This approach is not acceptable, however, unless the resulting double taxation is alleviated. The longstanding U.S. approach for handling the international double taxation problem is a foreign tax credit limited to …
Designing A 21st Century Corporate Tax – An Advance U.S. Minimum Tax On Foreign Income And Other Measures To Protect The Base, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Designing A 21st Century Corporate Tax – An Advance U.S. Minimum Tax On Foreign Income And Other Measures To Protect The Base, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship
The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This article continues our exploration of second best international tax reforms that would protect the U.S. corporate tax base and have some likelihood of adoption. In this case, we consider how a U.S. minimum tax on foreign income earned by a controlled foreign corporation should be designed to protect the United States against erosion of its corporate income tax base and to combat tax competition by low-tax intermediary countries. In the authors’ view, a minimum tax should be an interim levy that preserves the residual U.S. tax …
Reinvigorating Tax Expenditure Analysis And Its International Dimension, J. Clifton Fleming Jr., Robert J. Peroni
Reinvigorating Tax Expenditure Analysis And Its International Dimension, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship
Tax expenditure analysis (TEA) was rigorously criticized from its inception and continues to draw negative reviews. Notwithstanding this criticism, the Congressional Budget and Impoundment Control Act of 1974 requires the President's annual budget submission to contain a list of tax expenditures, and Congress's Joint Committee on Taxation has produced its own tax expenditure list each year since 1972. Although TEA has not restrained or reversed the growth of tax expenditures, TEA continues to play a major role in tax policy debates to the chagrin of its detractors. The persistence of TEA in a hostile environment suggests that it has meaningful …
American Offshore Business Tax Planning: Can Australian Lawyers Get A Piece Of The Action?, J Clifton Fleming, Jr.
American Offshore Business Tax Planning: Can Australian Lawyers Get A Piece Of The Action?, J Clifton Fleming, Jr.
Faculty Scholarship
No abstract provided.
Altering U.S. Treaty Policy To Permit The Negotiating Of Zero Withholding On Portfolio Dividends: An Invitation To Research, J. Clifton Fleming Jr.
Altering U.S. Treaty Policy To Permit The Negotiating Of Zero Withholding On Portfolio Dividends: An Invitation To Research, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.