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, written for a European conference on tax and corporate governance, evaluates two aspects of the U.S. legal response to corporate tax shelters: the civil penalty rules and the disclosure rules. It argues that, while the disclosure rules do not impose undue burdens, their usefulness to...

Curtailment or even repeal of the alternative minimum tax (AMT), the author believes, is only a matter of time. Due to inflationary bracket creep, the individual AMT in particular has an everwidening reach that Congress is unlikely to find politically tolerable. However, he notes, clear thinking...