Articles
International Corporate Income Tax Reform: Issues and Proposals
469–496
AbstractWhile details have changed from time to time, the basic treatment of foreign source income in the United States tax code has remained...
Allocating Business Profits for Tax Purposes: A Proposal to Adopt a Formulary Profit Split
497–553
AbstractThe current system of taxing the income of multinational firms in the United States is flawed across multiple dimensions. The system provides an...
Democracy, Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation
555–596
AbstractVirtually all efforts to confront and curb tax competition effectively require some measure of cooperation among nation-states. Regardless of...