Tax Reform: International Tax Issues and Some Proposals

Dilworth, Robert H.
January 2009
International Tax Journal;Jan2009, Vol. 35 Issue 1, p5
Academic Journal
The article discusses the ways to make fundamental changes in federal income taxation of income from cross-border trade and investment in the U.S. The author states that to invest in foreign Multinational Corporation (MNC) business entities engage in global direct investment, which are not subject to residual U.S. tax on their worldwide income, the tax-exempt pools of U.S.-resident capital must not have U.S. tax-based incentives. The author suggests that the country may tax all business income, domestic or foreign and must also allow a foreign tax credit.


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