Today we live in a globalizing economy: national open markets are steadily developing towards a global market. Within the European Union, the internal market without internal frontiers has been established. However, the fiscal sovereignty of nation states remains limited to economic activities...

There are both theoretical and practical tax policy considerations that favour a broad recognition for the value of corporate income tax losses — including for businesses operated within corporate groups. Ideally, an equitable and economically efficient tax system could obviate the need for...

Partnerships play an increasingly vital role in the federal income tax. Yet partnership taxation is deeply flawed, with enormously complicated provisions that strain the voluntary compliance mechanism on which the federal income tax relies. This article takes some early steps toward reform,...

We investigate the motivation for and outcome of corporate participation in shaping tax policy via lobbying. We posit that generally tax-sophisticated firms lobby on tax issues and that their motives for doing so are either to obtain a tax benefit or to avoid losing one. We label these motives...

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...

In this report, Fleming, Peroni, and Shay analyze the effects of including a final, low-rate minimum tax on U.S. multinational corporations in a territorial system. They continue to prefer a real worldwide international tax system, but see a final, low-rate minimum tax as a second-best measure...

In 1992, the Treasury Department proposed a comprehensive business income tax, or CBIT, as a reform option for the taxation of business income. In Treasury's proposal, all taxes on business income (including income of sole proprietorships) would be replaced by a flat, entity-level tax. Interest...