This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as...

NOTE: This paper is an unfinished work of William D. Andrews, who was the Eli Goldston Professor of Law at Harvard Law School and a premier tax scholar of his generation. This substantial but not fully completed manuscript was found among his papers after his death on May 20, 2017. It examines...