Debate about U.S. international tax policy often emphasizes norms, such as capital export neutrality (CEN) and capital import neutrality (CIN), that relate to worldwide welfare rather than U.S. national welfare. While this focus may seem paradoxical, or at least surprisingly altruistic in a...

International tax policy experts often mistakenly conflate two distinct margins: (1) the overall tax burden on outbound investment, and (2) the marginal reimbursement rate (MRR) for foreign taxes paid, which is 100 percent under a foreign tax credit system, but equals the marginal tax rate for...

This paper, published in Tax Notes on July 2, 2018, is the first half of a two-part paper examining and analyzing the three main international provisions in the 2017 tax act. Part 1, contained herein, discusses normative frameworks for international tax policy. Part 2 will focus on the base...