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United States

University of Michigan Law School

Taxation-Transnational

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The Three Goals Of Taxation, Reuven S. Avi-Yonah Jan 2006

The Three Goals Of Taxation, Reuven S. Avi-Yonah

Articles

The current debate in the United States about whether the income tax should be replaced with a consumption tax has been waged on the traditional grounds for evaluating tax policy: efficiency, equity, and administrability. For example, Joseph Bankman and David Weisbach recently argued for the superiority of an ideal consumption tax over an ideal income tax on three grounds: First, that the consumption tax is more efficient because it does not discriminate between current and future consumption,' while both income and consumption taxes have identical effect on work effort. Second, that the consumption tax is at least as good at …


All Of A Piece Throughout: The Four Ages Of U.S. International Taxation, Reuven S. Avi-Yonah Jan 2005

All Of A Piece Throughout: The Four Ages Of U.S. International Taxation, Reuven S. Avi-Yonah

Articles

This paper divides up the history of U.S. international taxation into four periods, on the basis of what was the basic theoretical principle underlying the major legislative enactments made in each period. The first period lasted from the adoption of the Foreign Tax Credit in 1918 to the end of the Eisenhower Administration, and was dominated by the concept of the right to tax as flowing from benefits conferred by the taxing state. The second period lasted from 1960 until the end of the Carter Administration, and was dominated by the concept of capital export neutrality and an emphasis on …