The Committee's planned international tax reform draft (Draft) will undoubtedly suggest some transition from the present deferral system to some other system. As an integral part of that transition, it is expected as well that the Draft will impose taxation on all “accumulated deferred foreign...

This concise submission shows that from many tax policy standpoints a residence-based tax system would be significantly better than a territorial-based tax system. Policy issues mentioned include:-- competitiveness, -- broadening of the tax base so the rate can be lowered,-- domestic job loss--...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

This article focuses solely on the big picture issue of whether international tax reform should take the form of a territorial system or an alternative full inclusion system. Of course, it is also necessary to compare these possible new systems with the current hybrid deferral system that has...

The Baucus Discussion Draft on international tax reform includes a mechanism for taxing the accumulated foreign earnings of controlled foreign corporations as of the effective date that a new system for taxing foreign earnings is effective.This letter suggests changes to make this aspect of the...

I am commenting on the form that International Tax Reform should take. In brief, the territorial system strongly lobbied for by the U.S.-based multinational corporations (MNCs) standing to benefit from such a system is not what is best for our country or our society. It is bad tax policy in...

This submission to the House Ways & Means Committee following its June 13, 2013 "Hearing on Tax Reform: Tax Havens, Base Erosion and Profit-Shifting" adds some practical points to supplement what Professor Kleinbard presented at the hearing regarding his recommended worldwide tax consolidation...

The territorial system strongly lobbied for by U.S. multinational corporations that stand to benefit from that system is not what's best for our country or our society. It is bad tax policy for many reasons, including the strong motivation it provides our multinational corporations to continue...

The OECD Base Erosion and Profit Shifting Project is now under way, its mission being to suggest ways that countries can work together and amend their domestic laws to combat the corporate profit shifting that has so affected the tax bases of many countries.The only way to truly eliminate...