This paper proposes an analysis of two major tax events which occurred in the European Union in 2001, the move of Germany from imputation to exemption and the objective announced by the EU Commission to provide EU businesses with a consolidated corporate tax base for their EU-wide activities. In...

In 2001, the European Commission proposed replacing the current system of taxation of multinational companies by the taxation of a consolidated base, computed at the level of all the European entities of a multinational enterprise, and then distributed for taxation purposes among the various...

This paper investigates replacing separate taxation by consolidation and formulary apportionment in a Bottom-up Federation, when a multijurisdictional firm is mobile in various respects. The reform is decided cooperatively by all the jurisdictions or by some of them, while tax rates remain...

In 2001, the European Commission proposed replacing the current system of taxation of multinational companies by the taxation of a consolidated base, computed at the level of all the European entities of a multijurisdictional enterprise, and then distributed for taxation purposes between the...

A surprising degree of bipartisan consensus has lately formed in the United States around two propositions of business tax reform: that something should be done about the “lockout” of U.S. multinationals' foreign earnings; and that (for reasons that go beyond lockout) the corporate income...

This work undertakes a comprehensive analysis of the U.S. state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may...

The cash-flow tax has been proposed as an alternative to corporate income tax on grounds of clarity and simplicity in defining the tax base in the face of widespread departures from the comprehensive income tax in actual practice. Variants of the tax, with their advantages and disadvantages,...

The author, in this article, examines Japan's Tax Reform 2009/10, with special reference to the background to the reform, the relevant legislative amendments regarding the taxation of controlled foreign subsidiaries and the implications of the reform for the future

The game Prisoner's Dilemma provides a helpful tool for understanding international tax competition. Nations would be best served by cooperating with each other to keep corporate income tax rates high. But fearing defection by other nations, many nations often unilaterally lower their corporate...