International Income Taxation

Posted: 17 May 2004

See all articles by Michael J. Graetz

Michael J. Graetz

Columbia Law School; Yale Law School

Abstract

The author discusses the issues impacting the development of international tax policy. He states that the proper question in forming international tax policy should be, "what policy is in the United States' national interest?" However, advancing the competitive position of U.S. multinationals may or may not be the right answer, depending on the issue and the circumstances. The author looks at the taxation of business income, and the relative merits of our credit system versus an exemption system, then explores the taxation of portfolio income. He notes that the U.S. international income tax system is built on irrelevant concepts, discussing specifically, corporate residence and source classifications. And, he finds that policymakers in the U.S. are insufficiently alert to the impact of international organizations such as the World Trade Organization and the European Court of Justice. Finally, he observes that the U.S. has the wrong mix of taxes, relying to heavily on income taxes and not nearly enough on a consumption tax.

Suggested Citation

Graetz, Michael J., International Income Taxation. Available at SSRN: https://ssrn.com/abstract=547282

Michael J. Graetz (Contact Author)

Columbia Law School ( email )

435 West 116th Street
New York, NY 10025
United States

Yale Law School ( email )

P.O. Box 208215
New Haven, CT 06520-8215
United States

HOME PAGE: http://www.law.yale.edu/faculty/MGraetz.htm

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