Deferral and Exemption of the Income of Foreign Subsidiaries: A Review of the Basic Analytics

11 Pages Posted: 4 Feb 2014 Last revised: 20 Jun 2014

Date Written: February 3, 2014

Abstract

Current proposals to replace the U.S. foreign tax credit with an exemption for the income of foreign subsidiaries of U.S. companies make timely a review of the basic analytics of taxation under the two systems. This brief note reviews the key relationships, highlighting some that are not always fully appreciated in policy discussions.

Suggested Citation

Warren, Alvin C., Deferral and Exemption of the Income of Foreign Subsidiaries: A Review of the Basic Analytics (February 3, 2014). Harvard Public Law Working Paper No. 14-18. Available at SSRN: https://ssrn.com/abstract=2390021 or http://dx.doi.org/10.2139/ssrn.2390021

Alvin C. Warren (Contact Author)

Harvard Law School ( email )

1575 Massachusetts
Hauser Hall 308
Cambridge, MA 02138
United States

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