U.S. International Tax Reform: What Form Should it Take?

Abstract

This article focuses solely on the big picture issue of whether international tax reform should take the form of a territorial system or an alternative full inclusion system. Of course, it is also necessary to compare these possible new systems with the current hybrid deferral system that has been in place for many years.

With little if any explanation of how it might be better for our nation and society as a whole, many persons and commentators whose companies or clients stand to benefit have called for a territorial system. Such persons have included CEOs, members of the professional tax community, business groups, and lobbyists. This article attempts to assess this issue on a more objective basis through a balanced understandable summary of the principal policy issues and consequences.

Keywords: International Taxation, International Tax Policy, Territorial System, Full Inclusion System