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
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: H25working papers series
Date posted: March 5, 2013 ; Last revised: March 7, 2013
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