Altshuler, Rosanne; Grubert, Harry - In: National Tax Journal 63 (2010) 4, pp. 1145-1184
This analysis of formula apportionment compared to the current U.S. system recognizes that income shifting has two main … sources, excess returns attributable to intangibles and debt, and that a major goal of income division systems is preserving … neutrality between arm’s length and related party transactions. A model demonstrates that separate accounts (SA) and formula …