In January 2003, the Bus Administration proposed a new system for taxing corporate dividends, under which domestic shareholders in U.S. corporations would not be taxed on dividends they received, provided the corporation distributed these dividends out of after-tax earnings (the "Bush...

The purpose of this article is to introduce to the international lawyer the somewhat different set of categories (e.g., residence and source rather than nationality and territoriality) employed by international tax lawyers, and explain the reasons for some of the differences. At the same time,...

This article attempts to provide the first comprehensive rationale for defending the current corporate income tax. It argues that the usual reasons given for the tax (primarily as an indirect way of taxing shareholders, or alternatively as a form of benefit tax) are inadequate. It then explains...

In January 2003, the Bush Administration proposed a new system for taxing corporate dividends, under which domestic shareholders in U.S. corporations would not be taxed on dividends they received, provided the corporation distributed these dividends out of after-tax earnings (the “Bush...

In Global Perspectives on Income Taxation Law, Reuven Avi-Yonah, Nicola Sartori, and Omri Marian cover basic, corporate and international tax law from a comparative perspective. The book both supplements readings in US tax law courses and serves as a textbook for a comparative tax law class. The...

The author shows that a progressive income tax has had little effect on after-tax income inequality. Social programs, however, do create a more equal society. He proposes a national sales tax—a value-added tax—to finance more such social programs as America's best route to a more equal society.

Commentary on an analysis of the implications of adoption by the U.S. of a consumption tax. Notes the superiority of a destination-based versus an origin-based consumption tax, and the likelihood that other countries may respond by terminating their income tax treaties with the U.S.

A central premise of tax scholarship of the last thirty years has been the greater mobility of capital than labour. Recently, scholars such as Edward Kleinbard have recommended that the US adopt a variant of the “dual income tax” model used by the Scandinavian countries, under which income...

This paper gives an overview and current status of foreign direct investment (FDI) in Latin America. It discusses the competition among the countries for FDI based on tax considerations and how this competition often contrasts the standards set in the World Trade Organization.

The current age of globalization can be distinguished from the previous one by the much higher mobility of capital than labor. The mobility of capital has led to tax competition, in which sovereign countries lower their tax rates on income earned by foreigners within their borders in order to...