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Formulary Apportionment – Myths And Prospects, Reuven S. Avi-Yonah, Ilan Benshalom
Formulary Apportionment – Myths And Prospects, Reuven S. Avi-Yonah, Ilan Benshalom
Law & Economics Working Papers
This paper seeks to re-examine the formulary alternative to transfer pricing by inquiring whether partial integration of formulary concepts into current practices would offer a reasonable alternative to transfer pricing rules. We believe that the key to achieving an equitable and efficient allocation of MNE income is to solve the problem of the residual, i.e., how to allocate income generated from mobile assets and activities whose risks are born collectively by the entire MNE group. These assets and activities generate most of the current transfer pricing compliance and administrative costs, as well as tax avoidance opportunities. A limited formulary tax …
Tax Convergence And Globalization, Reuven S. Avi-Yonah
Tax Convergence And Globalization, Reuven S. Avi-Yonah
Law & Economics Working Papers
This paper addresses three questions: 1. Is there evidence that the tax systems of different countries have converged (i.e., become more similar) in the period 1980-2010? 2. If so, what is the explanation for this convergence? 3. Is convergence a positive or negative development?
The Case Against Taxing Citizens, Reuven S. Avi-Yonah
The Case Against Taxing Citizens, Reuven S. Avi-Yonah
Law & Economics Working Papers
The US is the only developed country to tax citizens living permanently overseas on their worldwide income. This rule was created at a time when the income tax applied only to the rich and when some of the rich moved overseas to avoid the draft. We do not have a draft any more, the income tax applies to the middle class, and many more US citizens live permanently overseas for non-tax reasons. In a globalized world, citizenship-based taxation is an anachronism which should be abandoned.