Considering "Reconsidering the Taxation of Foreign Income"
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.
Number of Pages in PDF File: 18Accepted Paper Series
Date posted: September 12, 2012
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