Fixing U.S. International Taxation

Hardcover | January 22, 2014

byDaniel N. Shaviro

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International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reformthe U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguidedinsofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis.Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving theprevailing rules, both in the U.S. and around the world.

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International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reformthe U.S. tax rules is stuck in a sterile di...

Daniel N. Shaviro is the Wayne Perry Professor of Taxation at New York University School of Law. Prof. Shaviro's scholarly work examines tax policy, budget policy, and entitlements issues. Before entering teaching of law, he spent three years in private practice at Caplin and Drysdale, a leading tax specialty firm, and three years as ...

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Format:HardcoverDimensions:224 pages, 9.25 × 6.12 × 0.98 inPublished:January 22, 2014Publisher:Oxford University PressLanguage:English

The following ISBNs are associated with this title:

ISBN - 10:019935975X

ISBN - 13:9780199359752

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Table of Contents

Acknowledgments1. Introduction and OverviewPart One: The Rules and Their Main Effects2. The Main Building Blocks of U.S. International Taxation3. Planning and Policy Issues Under the Existing U.S. RulesPart Two: Developing and Applying a Policy Framework4. The Global Welfare Perspective5. The Unilateral National Welfare Perspective6. What Is To Be Done?BibliographyIndex