Does More Sophisticated Mean Better? A Critique of Alternative Approaches to Sourcing the Interest Expense of American Multinationals
New York University School of Law
This article discusses, from an economic perspective but with considerable legal detail, the United States income tax rules for "sourcing" deductions for interest expense incurred by American multinationals. Among other points, it shows that the "fungibility" standard for interest allocation that has been unquestioned for several decades lacks any persuasive normative foundation.
Number of Pages in PDF File: 83
JEL Classification: H20, H21, H25working papers series
Date posted: February 6, 2001
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