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International Income Taxation, Michael Graetz
International Income Taxation, Michael Graetz
Faculty Scholarship
Much of what I will say here today is distilled from articles that I have written and things I have learned in putting together a book called Foundations of International Taxation.
It is difficult enough to fashion sensible tax policy in the domestic arena. The debate, for example, over whether the United States should impose a value-added tax has some international aspects, but it is primarily a debate about domestic policy. This is true generally about the debate over how much we should rely on income versus consumption taxation. This debate amply illustrates how hard it is to obtain agreement …
Taxing International Income: Inadequate Principles, Outdated Concepts, And Unsatisfactory Policies, Michael J. Graetz
Taxing International Income: Inadequate Principles, Outdated Concepts, And Unsatisfactory Policies, Michael J. Graetz
Faculty Scholarship
It is a pleasure to be here today to deliver the first David R. Tillinghast Lecture of the 21st century, a lecture honoring a man who has done much to shape' and stimulate our thinking about the international tax world of the 20th.
Our nation's system for taxing international income today is largely a creature of the period 1918-1928; a time when the income tax was itself in childhood. From the inception of the income tax (1913 for individuals, 1909 for corporations) until 1918, foreign taxes were deducted like any other business expense. In 1918, the foreign tax credit (FTC) …