Abstract

http://ssrn.com/abstract=2228082
 


 



FIRPTA, Branch Profit Tax and Earning Stripping: Reflections on Non-Discrimination


Reuven S. Avi-Yonah


University of Michigan Law School

March 4, 2013

U of Michigan Public Law Research Paper No. 319

Abstract:     
In the 1980s, the United States enacted three modifications to its taxation of non-residents that are arguably discriminatory. This paper discusses which of them were actually discriminatory and what the proper criterion for tax discrimination should be. It suggests that the key question should be whether a payment to a non-resident is taxable in its country of residence in the way that a payment to a resident is taxable in the country imposing the arguably discriminatory tax.

Number of Pages in PDF File: 5

Keywords: tax discrimination

JEL Classification: H25

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Date posted: March 5, 2013 ; Last revised: March 7, 2013

Suggested Citation

Avi-Yonah, Reuven S., FIRPTA, Branch Profit Tax and Earning Stripping: Reflections on Non-Discrimination (March 4, 2013). U of Michigan Public Law Research Paper No. 319. Available at SSRN: http://ssrn.com/abstract=2228082 or http://dx.doi.org/10.2139/ssrn.2228082

Contact Information

Reuven S. Avi-Yonah (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)
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