Observers of international tax rules have long conflated two distinct effects of the foreign tax credit on multinational firms: the effect on the incentive to invest abroad and the effect on foreign tax sensitivity. With national welfare as the policy objective, we discuss how a burden neutral...

This is a slightly revised version of a lunch talk that the author gave at the National Tax Association's 46th Annual Spring Symposium on May 12. It addresses, among other topics, why there is so little consensus regarding international tax policy, and what lessons we learn from the recent wave...

This paper, published in Tax Notes on July 9, 2018, is the second half of a two-part paper examining and analyzing the three main international provisions in the 2017 tax act. Part 1 discussed normative frameworks for international tax policy. Part 2, contained herein, focuses on the base...