The Resource Stateless income's challenge to tax policy, part 2

Stateless income's challenge to tax policy, part 2

Label
Stateless income's challenge to tax policy, part 2
Title
Stateless income's challenge to tax policy, part 2
Creator
Subject
Language
  • eng
  • eng
Summary
In this second part of a two-part special report, the author considers the tax consequences and policy implications of the phenomenon of "stateless income." This section analyses the problems that stateless income poses for standard efficiency benchmarks. It demonstrates that conclusions that are logical in a world without stateless income do not follow once the presence of stateless income tax planning is considered. The capital ownership neutrality standard has much to recommend it in theory. But it contains an underappreciated assumption that source country taxation is fully capitalized into the prices of firms operating in that source country. Phrased alternatively, the capital ownership neutrality model assumes that multinational firms face a constant after-tax rate of return everywhere in the world and suffer the same tax burden everywhere, when "tax" for this purpose is defined to include both explicit and implicit taxes. This report argues that stateless income tax planning vitiates the plausibility of this critical assumption
Citation source
In: Tax notes international. - Falls Church. - Vol. 68 (2012),
http://library.link/vocab/creatorName
Kleinbard, E.D
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • stateless income
  • international tax planning
  • tax policy
  • thin capitalization
  • CFC
  • formulary apportionment
  • worldwide income
  • residence
  • foreign tax credit
Label
Stateless income's challenge to tax policy, part 2
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2012/T/TNI/vol.68/7_671-687.zip
Publication
Note
20121224

Library Locations

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