On Fixing U.S. International Taxation

Abstract

This paper was prepared for a book symposium at Hebrew University Law School in June 2013 on Daniel N. Shaviro’s forthcoming book, Fixing U.S. International Taxation (Oxford University Press, 2014). The paper adds a few thoughts to those discussed in the book regarding the international tax neutrality analysis and certain interrelated notions concerning deferral, foreign tax credits, foreign tax deductions, and the tax rate on foreign source income.

Keywords: International taxation, international tax neutrality, deferral, foreign tax credit, foreign tax deductions, tax rate, foreign source income