Considering "Reconsidering the Taxation of Foreign Income"

Mitchell Kane

New York University (NYU)


Tax Law Review, Vol. 62, 2009

This comment responds to the article “Reconsidering the Taxation of Foreign Income” by James Hines. It analyzes the two central policy implications of that article: (i) that the United States should adopt a territorial regime of taxation and (ii) that under an exemption system the United States should not disallow general interest expense allocated to foreign source income. The comment concludes that the ownership neutrality analysis advanced by Hines is not adequate to defend these two policy prescriptions.

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Date posted: September 12, 2012  

Suggested Citation

Kane, Mitchell, Considering "Reconsidering the Taxation of Foreign Income" (2009). Tax Law Review, Vol. 62, 2009. Available at SSRN: http://ssrn.com/abstract=2145394

Contact Information

Mitchell Kane (Contact Author)
New York University (NYU) ( email )
Bobst Library, E-resource Acquisitions
20 Cooper Square 3rd Floor
New York, NY 10003-711
United States
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