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10 Results
IRS
U.S. Supreme Court Unanimously Chooses Substance Over Form in Foreign Tax Credit Case: Implications of the PPL Decision for the Creditability of Cash-flow Taxes
This paper examines the effects of a U.S. Supreme Court ruling that a one-time retroactive British “Windfall Tax” levied on 32 public utilities that were privatized between 1984 and 1996 was eligible for the US foreign tax credit (FTC). The decision could have far-reaching implications for the creditability of taxes that are not ordinarily thought to be income taxes, including various cash-flow business taxes that are key elements of several proposals recommending replacement of the income tax with a consumption-based tax.
Charles E. McLure, Jr., Jack Mintz, George R. Zodrow August 20, 2014
The Case for Corporate Income Tax Reform
The positive effects of a corporate income tax reform in the United States might well be enhanced by a simultaneous move to a territorial system coupled with anti-base erosion provisions designed to limit revenue losses; however, the effects of implementing territoriality are tenuous and seem likely to be small in the aggregate. Published by the American Action Forum.
John W. Diamond, George R. Zodrow May 29, 2013